BILL LOCKYER, Attorney General - California State … · BILL LOCKYER, Attorney General of the...
Transcript of BILL LOCKYER, Attorney General - California State … · BILL LOCKYER, Attorney General of the...
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BILL LOCKYER Attorney General of the State of California
JAMI L CANTORE State Bar No 165410 Deputy Attorney General
California Department of Justice 300 So Spring Street Suite 1702 Los Angeles CA 90013 Telephone (213) 897-2569 Facsimile (213) 897-2804
Attorneys for Complainant
BEFORE THE BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA
In the Matter of the Accusation Against
CHRISTIAN BEVAN WILLIAMS 9 Poinsettia Gardens Drive Ventura CA 93004
and
clo Sierra Conservation Center Inmate Reg No V50004 PO Box 497 5100 O-Bylnes Ferry Road Jamestown CA 95327
Pharmacy Technician Registration No TCH 44940
Respondent
Case No 2871
DEFAULT DECISION AND ORDER
[GoY Code sect11520]
FINDINGS OF FACT
1 On or about November 10 2005 Complainant Patricia F Harris in her
official capacity as the Executive Officer of the Board of Pharmacy Department of Consumer
Affairs filed Accusation No 2871 against Christian Bevan Williams (Respondent) before the
Board of Pharmacy
2 On or about October 22 2002 the Board of Pharmacy (Board) issued
Pharmacy Technician Registration No TCH 44940 to Respondent On or about July 25 2005
pursuant to Business and Professions Code section 4311 subdivision (a) the Board issued a
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Notice of Automatic Suspension of License Phannacy Technician Registration No TCH 44940
will expired on April 30 2006 unless renewed
3 On or about November 302005 MariaElena Hernandez an employee of
the Department of Justice served by Certified and First Class Mail a copy of the Accusation No
2871 Statement to Respondent Notice of Defense Request for Discovery and Government
Code sections 115075 115076 and 115077 to Respondents address of record with the Board
which was and is 9 Poinsettia Gardens Drive Ventura CA 93004 The Accusation and related
documents were also served on Respondent co Sierra Conservation Center Inmate Reg No V
50004 P O Box 4975100 O-Bylnes Feny Road Jamestown CA 95327 A copy of the
Accusation is attached hereto as Exhibit A and is incorporated herein by reference
4 On or about December 5 2005 the aforementioned documents were
received by Respondent at the following address Siena Conservation Center Inmate Reg No
V 50004 P O Box 4975100 O-Byrnes Ferry Road Jamestown CA 95327 A copy of the
Domestic Return Receipt is attached hereto as Exhibit B and incorporated herein by reference
5 Service of the Accusation was effective as a matter of law under the
provisions of Government Code section 11505 subdivision (c)
6 Business and Professions Code section 118 states in pertinent part
(b) The suspension expiration or forfeiture by operation of law of a license
issued by a board in the depatiment or its suspension forfeiture or cancellation by order of the
board or by order of a court of law or its surrender without the written consent of the board shall
not during any period in which it may be renewed restored reissued or reinstated deprive the
board of its authority to institute or continue a disciplinary proceeding against the licensee upon
any ground provided by law or to enter an order suspending or revoking the license or otherwise
taking disciplinary action against the license on any such ground
7 Government Code section 11506 states in peliinent part
( c) The respondent shall be entitled to a hearing on the merits if the respondent
files a notice of defense and the notice shall be deemed a specific denial of all parts of the
accusation not expressly admitted Failure to file a notice of defense shall constitute a waiver of
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respondents right to a hearing but the agency in its discretion may nevetihe1ess grant a hearing
8 Respondent failed to file a Notice of Defense within 15 days after service
upon him of the Accusation and therefore waived his right to a hearing on the merits of
Accusation No 2871
9 California Government Code section 11520 states in pertinent part
(a) If the respondent either fails to file a notice of defense or to appear at the
hearing the agency may take action based upon the respondents express admissions or upon
other evidence and affidavits may be used as evidence without any notice to respondent
10 Pursuant to its authority under Government Code section 11520 the Board
finds Respondent is in default The Board will take action without further hearing and based on
Respondents express admissions by way of default and the evidence before it contained in
Exhibits A and B finds that the allegations in Accusation No 2871 are true
11 The total costs for investigation and enforcement are $218250 as of
March 8 2006
DETERMINATION OF ISSUES
1 Based on the foregoing findings of fact Respondent Christian Bevan
Williams has subjected his Phatmacy Technician Registration No TCH 44940 to discipline
2 A copy of the Accusation is attached
3 The agency has jurisdiction to adjudicate this case by default
4 The Board of Pharmacy is authorized to revoke Respondents Pharmacy
Technician Registration based upon the following violations alleged in the Accusation
a Business and Professions Code sections 4301 subdivision (1) and 490
conviction(s) of substantially related crimes - assault with a firearm driving under the influence
and possession of marijuana
b Business and Professions Code sections 4301 subdivision (j) and 4060
possession of a controlled substance Marijuana
c Business and Professions Code sections 4301 subdivision (t) acts
involving moral turpitude dishonesty fraud deceit or corruption
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DECISION AND ORDER
IT IS SO ORDERED that Pharmacy Technician Registration No TCH 44940
heretofore issued to Respondent Christian Bevan Williams is revoked
Pursuant to Government Code section 11520 subdivision (c) Respondent may
serve a written motion requesting that the Decision be vacated and stating the grounds relied on
within seven (7) days after service of the Decision on Respondent The agency in its discretion
may vacate the Decision and grant a hearing on a showing of good cause as defined in the
statute
This Decision shall become effective on -LMa~y~34-1-1_200JJ-6-----shy
It is so ORDERED ~M(daYt--middot41-----2lLlOOu6L--_____
BOARD OF PHARMACY DEPARTMENT OF CONSUMERAFFAlRS STATE OF CALIFORNIA
By
Board President
Attachments Exhibit A Accusation No 2871 Exhibit B Postal retulTI document
60135522wpd
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Exhibit A
Accusation No 2871
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BILL LOCKYER Attorney General of the State of California
JAMI L CANTORE State Bar No 165410 Deputy Attorney General
California Department of Justice 300 So Spring Street Suite 1702 Los Angeles CA 90013 Telephone (213) 897-2569 Facsimile (213) 897-2804
Attorneys for Complainant
BEFORE THE BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA
In the Matter of the Accusation Against
CHRISTIAN BEVAN WILLIAMS 9 Poinsettia Gardens Drive Ventura CA 93004
- andshy
co Sierra Conservation Center Inmate Reg No V50004 PO Box 497 5100 a-Byrnes Ferry Road Jamestown CA 95327
Pharmacy Technician Registration No TCH 44940
Respondent
Case No 2871
ACCUSATION
Complainant alleges
PARTIES
1 Patricia F Harris (Complainant) brings this Accusation solely in her
official capacity as the Executive Officer of the Board of Pharmacy Department of Consumer
Affairs (Board)
2 On or about October 222002 the Board issued Pharmacy Technician
Registration No TCH 44940 to Christian Bevan Williams (Respondent) On or about July 25
2005 pursuant to Business and Professions Code section 4311 subdivision (a) the Board issued
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a Notice ofAutomatic Suspension of License The Pharmacy Technician Registration will expire
on April 30 2006 unless renewed
JURISDICTION
3 This Accusation is brought before the Board under the authority of the
following laws All section references are to the Business and Professions Code unless otherwise
indicated
4 Section 4300 permits the Board to take disciplinary action to suspend or
revoke a license or permit
E Section 118 subdivision (b) provides that the suspension
expirationsurrendercancellation of a license shall not deprive the Board ofjurisdiction to
proceed with a disciplinary action during the period within which the license may be renewed
restored reissued or reinstated
F Section 490 states
A board may suspend or revoke a license on the ground that the licensee has been
convicted of a crime if the crime is substantially related to the qualifications functions or duties
of the business or profession for which the license was issued A conviction within the meaning
of this section means a plea or verdict of guilty or a conviction following a plea of nolo
contendere Any action which a board is permitted to take following the establishment of a
conviction may be taken when the time for appeal has elapsed or the judgment of conviction has
been affinned on appeal or when an order granting probation is made suspending the imposition
of sentence irrespective of a subsequent order under the provisions of Section 12034 of the
Penal Code
7 Section 4301 states in pertinent part
The board shall take action against any holder of a license who is guilty of
unprofessional conduct or whose license has been procured by fraud or misrepresentation or
issued by mistake Unprofessional conduct shall include but is not limited to any of the
following
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(f) The commission of any act involving moral turpitude dishonesty fraud
deceit or corruption whether the act is committed in the course of relations as a licensee or
otherwise and whether the act is a felony or misdemeanor or not
0) The violation of any of the statutes of this state or of the United States
regulating controlled substances and dangerous drugs
n(l) The conviction of a crime substantially related to the qualifications functions
and duties of a licensee under this chapter The record of conviction shall be conclusive
evidence only of the fact that the conviction occurred
nco) Violating or attempting to violate directly or indirectly or assisting in or
abetting the violation of or conspiring to violate any provision or term of this chapter or of the
applicable federal and state laws and regulations governing pharmacy including regulations
established by the board
(p) Actions or conduct that would have warranted denial of a license
8 Section 4060 states in pertinent part that [n]o person shall possess any
controlled substance except that furnished to a person upon the prescription of a physician
dentist podiatrist or veterinarian or furnished pursuant to a drug order issued by a certified
nurse-midwife pursuant to Section 274651 a nurse practitioner pursuant to Section 28361 or a
physician assistant pursuant to Section 35021
9 California Code of Regulations title 16 section 1770 states
For the purpose of denial suspension or revocation of a personal or facility
license pursuant to Division 15 (commencing with Section 475) of the Business and Professions
Code a crime or act shall be considered substantially related to the qualifications functions or
duties of a licensee or registrant if to a substantial degree it evidences present or potential
unfitness of a licensee or registrant to perform the functions authorized by his license or
registration in a manner consistent with the public health safety or welfare
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10 Section 475 states in pertinent part
(a) Notwithstanding any other provisions of this code the provisions of this
division shall govern the denial of licenses on the grounds of
(2) Conviction of a crime
(3) Commission of any act involving dishonesty fraud or deceit with the intent
to substantially benefit himself or another or substantially injure another
(4) Commission of any act which if done by a licentiate of the business or
profession inquestion would be grounds for suspension or revocation of license
11 Section 1253 states in pertinent part that the Board may request the
administrative law judge to direct a licentiate found to have committed a violation or violations
of the licensing act to pay a sum not to exceed the reasonable costs of the investigation and
enforcement of the case
CONTROLLED SUBSTANCES I DANGEROUS DRUGS
12 Marijuana is a hallucinogenic Schedule I controlled substance as defined
in Health and Safety Code section 11054(d)(13) and a dangerous drug according to Business and
Professions Code section 4022
FIRST CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - Assault with a Firearm)
13 Respondent is subject to disciplinary action under section 4300490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1770 in that on or about July 1 2004 Respondent was
convicted of a crime substantially related to the qualifications functions or duties of a pharmacy
technician as follows
a On or about July 1 2004 in a criminal proceeding entitled The People of
the State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court Case
No2004014916FA Respondent was convicted on a plea of guilty for violating Penal Code
section 245( a)(2) (assault with a firearm) a felony and the special allegation of Penal Code
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section 12022S(a)(I) (use ofa firearm) a felony On or about August 30 2004 Respondent was
sentenced to serve five (5) years in the Department of Corrections
b The circumstances underlying the conviction are that on or about April 10
2004 Respondent was arrested after making violent andor death threats brandishing a Glock 40
caliber pistol and during a physical altercation shooting victim Michael M in the left shoulder
with the pistol
SECOND CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - DUI)
14 Respondent is subject to disciplinary action under section 4300 490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1770 in that on or about February 5 2003 Respondent
was convicted of a crime substantially related to the qualifications functions or duties of a
pharmacy technician as follows
a On or about February 5 2003 in a criminal proceeding entitled The
People ofthe State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court
Case No 2003001701 MA Respondent was convicted on a plea of guilty for violating Vehicle
Code section 23152b) (driving while having a 008 or higher blood alcohol content) a
misdemeanor
b The circumstances underlying the conviction are that on or about
January 52003 Respondent was arrested for driving under the influence of an alcoholic
beverage Respondents blood alcohol content tested at 013
TIDRD CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - Possession of Marijuana)
15 Respondent is subject to disciplinary action under section 4300 490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1710 in that on or about February 2 2000 Respondent
was convicted of a crime substantially related to the qualifications functions or duties of a
phatmacy technician as follows
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a On or about February 2 2000 in a criminal proceeding entitled The
People ofthe State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court
Case No 00M009643MA Respondent was convicted on a plea of guilty for violating Vehicle
code section 23222(b) (possession of marijuana in vehicle) a misdemeanor
b The circumstances underlying the conviction are that on or about
January 5 2000 Respondent was in possession of the controlled substance and dangerous drug
marijuana while driving a vehicle
FOURTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Possessions of Controlled Substance I Dangerous Drug - Marijuana)
16 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision 0) on the grounds of unprofessional conduct for violating section 4060 in that on or
about January 5 2000 Respondent was in possession of marijuana a controlled substance and
dangerous drug without a valid prescription
FIFTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Dishonest Acts)
17 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision (f) on the grounds of unprofessional conduct in that Respondent committed acts
involving moral turpitude dishonesty fraud deceit or corruption as set forth above in paragraphs
13 through 16 and incorporated herein by reference
SIXTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Acts Warranting Denial of Licensure)
18 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision (p) on the grounds of unprofessional conduct in conjunction with section 475
subdivisions (a)(2) (a)(3) and (a)(4) in that Respondent committed acts which would warrant
denial of licensure as set forth above in paragraphs 13 through 17 and incorporated herein by
reference
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PRAYER
WHEREFORE Complainant requests that a hearing be held on the matters herein
alleged and that following the hearing the Board of Pharmacy issue a decision
A Revoking or suspending Pharmacy Technician Registration No TCH
44940 issued to Christian Bevan Williams
B Ordering Christian Bevan Williams to pay the Board of Pharmacy the
reasonable costs of the investigation and enforcement of this case pursuant to Business and
Professions Code section 1253
C Taking such other and further action as deemed necessary and proper
DATED 10105
PATRICIAF HARRIS Executive Officer Board of Pharmacy Department of Consumer Affairs State of California
Complainant
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DECLARATION OF SERVICE BY CERTIFIED MAIL AND FIRST CLASS MAIL (Separate Mailings)
Case Name In the Matter of the Accusation Against Christian Bevan Williams Case No 2871
I declare
I am employed in the Office of the Attorney General which is the office of a member of the California State Bar at which members direction this service is made I am 18 years of age or older and not a party to this matter I am familiar with the business practice at the Office of the Attorney General for collection and processing of correspondence for mailing with the United States Postal Service In accordance with that practice correspondence placed in the internal mail collection system at the Office of the Attorney General is deposited with the United States Postal Service that same day in the ordinary course ofbusiness
On November 30 2005 I served the attached Accusation Statement to Respondent Request for Discovery Notice of Defense and Government Code sections by placing a true copy thereof enclosed in a sealed envelope as certified mail with postage thereon fully prepaid and return receipt requested and another true copy of the Accusation Statement to Respondent Request for Discovery Notice of Defense and Government Code sections was enclosed in a second sealed envelope as first class mail with postage thereon fully prepaid in the internal mail collection system at the Office of the Attorney General at Los Angeles addressed as follows
Christian Bevan Williams 9 Poinsettia Gardens Drive Ventura CA 93004
Certified Mail Receipt No 7001 0360 0003 2701 4893
Christian Bevan Williams
Susan Cappello Enforcement Analyst Board of Pharmacy 400 R Street Suite 4070 Sacramento CA 95814-6200
=I CJ rshyru rn CJ CJ CJ
CJ D rn CJ
=I CJ CJ rshy
=I CJ rshyru rn Cl Cl Cl
Cl D rn Cl
r-=1 Cl Cl r-
Postmark HOl8 vs of the State of California the foregoing is tnle
ted on November 30 2005 at Los Angeles
Exhibit B
Postal Return Document
o Agent
o Addressee
D Is delivery address different from item 1 0 Yes
If YES enter delivery address below 0 No
~~lv0-wt)
Ace c~G~i-SENDER COMPLETE THIS SECTION
bull Complete items 1 2 and 3 Also complete item 4 if RestrictedDelivery is desired
bull Print your name and address on the reverse so that we can return the card to you
bull Attach this card to the back of the mail piece or on the front if space permits
1 Article Addressed to
Christian Bevan Villiams co Sierra Conservation Center Inmate Reg No V50004 PO Box 497 5100 O-Byrnes Ferry Road Jamestown CA 95327
3 Service Type
Ji( Certified Mail o Registered
o Insured Mail
Express Mail
COD
4 Restricted Delivery (Extra Fee) 0 Y
i Return Receipt for Merchandise
es
2 Article Number (Copy from service label) 7001 0360 0003 2701 4886
PS Form 3811 July 1999 Domestic Return Receipt 102595-00-M-0952
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Notice of Automatic Suspension of License Phannacy Technician Registration No TCH 44940
will expired on April 30 2006 unless renewed
3 On or about November 302005 MariaElena Hernandez an employee of
the Department of Justice served by Certified and First Class Mail a copy of the Accusation No
2871 Statement to Respondent Notice of Defense Request for Discovery and Government
Code sections 115075 115076 and 115077 to Respondents address of record with the Board
which was and is 9 Poinsettia Gardens Drive Ventura CA 93004 The Accusation and related
documents were also served on Respondent co Sierra Conservation Center Inmate Reg No V
50004 P O Box 4975100 O-Bylnes Feny Road Jamestown CA 95327 A copy of the
Accusation is attached hereto as Exhibit A and is incorporated herein by reference
4 On or about December 5 2005 the aforementioned documents were
received by Respondent at the following address Siena Conservation Center Inmate Reg No
V 50004 P O Box 4975100 O-Byrnes Ferry Road Jamestown CA 95327 A copy of the
Domestic Return Receipt is attached hereto as Exhibit B and incorporated herein by reference
5 Service of the Accusation was effective as a matter of law under the
provisions of Government Code section 11505 subdivision (c)
6 Business and Professions Code section 118 states in pertinent part
(b) The suspension expiration or forfeiture by operation of law of a license
issued by a board in the depatiment or its suspension forfeiture or cancellation by order of the
board or by order of a court of law or its surrender without the written consent of the board shall
not during any period in which it may be renewed restored reissued or reinstated deprive the
board of its authority to institute or continue a disciplinary proceeding against the licensee upon
any ground provided by law or to enter an order suspending or revoking the license or otherwise
taking disciplinary action against the license on any such ground
7 Government Code section 11506 states in peliinent part
( c) The respondent shall be entitled to a hearing on the merits if the respondent
files a notice of defense and the notice shall be deemed a specific denial of all parts of the
accusation not expressly admitted Failure to file a notice of defense shall constitute a waiver of
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respondents right to a hearing but the agency in its discretion may nevetihe1ess grant a hearing
8 Respondent failed to file a Notice of Defense within 15 days after service
upon him of the Accusation and therefore waived his right to a hearing on the merits of
Accusation No 2871
9 California Government Code section 11520 states in pertinent part
(a) If the respondent either fails to file a notice of defense or to appear at the
hearing the agency may take action based upon the respondents express admissions or upon
other evidence and affidavits may be used as evidence without any notice to respondent
10 Pursuant to its authority under Government Code section 11520 the Board
finds Respondent is in default The Board will take action without further hearing and based on
Respondents express admissions by way of default and the evidence before it contained in
Exhibits A and B finds that the allegations in Accusation No 2871 are true
11 The total costs for investigation and enforcement are $218250 as of
March 8 2006
DETERMINATION OF ISSUES
1 Based on the foregoing findings of fact Respondent Christian Bevan
Williams has subjected his Phatmacy Technician Registration No TCH 44940 to discipline
2 A copy of the Accusation is attached
3 The agency has jurisdiction to adjudicate this case by default
4 The Board of Pharmacy is authorized to revoke Respondents Pharmacy
Technician Registration based upon the following violations alleged in the Accusation
a Business and Professions Code sections 4301 subdivision (1) and 490
conviction(s) of substantially related crimes - assault with a firearm driving under the influence
and possession of marijuana
b Business and Professions Code sections 4301 subdivision (j) and 4060
possession of a controlled substance Marijuana
c Business and Professions Code sections 4301 subdivision (t) acts
involving moral turpitude dishonesty fraud deceit or corruption
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DECISION AND ORDER
IT IS SO ORDERED that Pharmacy Technician Registration No TCH 44940
heretofore issued to Respondent Christian Bevan Williams is revoked
Pursuant to Government Code section 11520 subdivision (c) Respondent may
serve a written motion requesting that the Decision be vacated and stating the grounds relied on
within seven (7) days after service of the Decision on Respondent The agency in its discretion
may vacate the Decision and grant a hearing on a showing of good cause as defined in the
statute
This Decision shall become effective on -LMa~y~34-1-1_200JJ-6-----shy
It is so ORDERED ~M(daYt--middot41-----2lLlOOu6L--_____
BOARD OF PHARMACY DEPARTMENT OF CONSUMERAFFAlRS STATE OF CALIFORNIA
By
Board President
Attachments Exhibit A Accusation No 2871 Exhibit B Postal retulTI document
60135522wpd
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Exhibit A
Accusation No 2871
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BILL LOCKYER Attorney General of the State of California
JAMI L CANTORE State Bar No 165410 Deputy Attorney General
California Department of Justice 300 So Spring Street Suite 1702 Los Angeles CA 90013 Telephone (213) 897-2569 Facsimile (213) 897-2804
Attorneys for Complainant
BEFORE THE BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA
In the Matter of the Accusation Against
CHRISTIAN BEVAN WILLIAMS 9 Poinsettia Gardens Drive Ventura CA 93004
- andshy
co Sierra Conservation Center Inmate Reg No V50004 PO Box 497 5100 a-Byrnes Ferry Road Jamestown CA 95327
Pharmacy Technician Registration No TCH 44940
Respondent
Case No 2871
ACCUSATION
Complainant alleges
PARTIES
1 Patricia F Harris (Complainant) brings this Accusation solely in her
official capacity as the Executive Officer of the Board of Pharmacy Department of Consumer
Affairs (Board)
2 On or about October 222002 the Board issued Pharmacy Technician
Registration No TCH 44940 to Christian Bevan Williams (Respondent) On or about July 25
2005 pursuant to Business and Professions Code section 4311 subdivision (a) the Board issued
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a Notice ofAutomatic Suspension of License The Pharmacy Technician Registration will expire
on April 30 2006 unless renewed
JURISDICTION
3 This Accusation is brought before the Board under the authority of the
following laws All section references are to the Business and Professions Code unless otherwise
indicated
4 Section 4300 permits the Board to take disciplinary action to suspend or
revoke a license or permit
E Section 118 subdivision (b) provides that the suspension
expirationsurrendercancellation of a license shall not deprive the Board ofjurisdiction to
proceed with a disciplinary action during the period within which the license may be renewed
restored reissued or reinstated
F Section 490 states
A board may suspend or revoke a license on the ground that the licensee has been
convicted of a crime if the crime is substantially related to the qualifications functions or duties
of the business or profession for which the license was issued A conviction within the meaning
of this section means a plea or verdict of guilty or a conviction following a plea of nolo
contendere Any action which a board is permitted to take following the establishment of a
conviction may be taken when the time for appeal has elapsed or the judgment of conviction has
been affinned on appeal or when an order granting probation is made suspending the imposition
of sentence irrespective of a subsequent order under the provisions of Section 12034 of the
Penal Code
7 Section 4301 states in pertinent part
The board shall take action against any holder of a license who is guilty of
unprofessional conduct or whose license has been procured by fraud or misrepresentation or
issued by mistake Unprofessional conduct shall include but is not limited to any of the
following
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(f) The commission of any act involving moral turpitude dishonesty fraud
deceit or corruption whether the act is committed in the course of relations as a licensee or
otherwise and whether the act is a felony or misdemeanor or not
0) The violation of any of the statutes of this state or of the United States
regulating controlled substances and dangerous drugs
n(l) The conviction of a crime substantially related to the qualifications functions
and duties of a licensee under this chapter The record of conviction shall be conclusive
evidence only of the fact that the conviction occurred
nco) Violating or attempting to violate directly or indirectly or assisting in or
abetting the violation of or conspiring to violate any provision or term of this chapter or of the
applicable federal and state laws and regulations governing pharmacy including regulations
established by the board
(p) Actions or conduct that would have warranted denial of a license
8 Section 4060 states in pertinent part that [n]o person shall possess any
controlled substance except that furnished to a person upon the prescription of a physician
dentist podiatrist or veterinarian or furnished pursuant to a drug order issued by a certified
nurse-midwife pursuant to Section 274651 a nurse practitioner pursuant to Section 28361 or a
physician assistant pursuant to Section 35021
9 California Code of Regulations title 16 section 1770 states
For the purpose of denial suspension or revocation of a personal or facility
license pursuant to Division 15 (commencing with Section 475) of the Business and Professions
Code a crime or act shall be considered substantially related to the qualifications functions or
duties of a licensee or registrant if to a substantial degree it evidences present or potential
unfitness of a licensee or registrant to perform the functions authorized by his license or
registration in a manner consistent with the public health safety or welfare
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10 Section 475 states in pertinent part
(a) Notwithstanding any other provisions of this code the provisions of this
division shall govern the denial of licenses on the grounds of
(2) Conviction of a crime
(3) Commission of any act involving dishonesty fraud or deceit with the intent
to substantially benefit himself or another or substantially injure another
(4) Commission of any act which if done by a licentiate of the business or
profession inquestion would be grounds for suspension or revocation of license
11 Section 1253 states in pertinent part that the Board may request the
administrative law judge to direct a licentiate found to have committed a violation or violations
of the licensing act to pay a sum not to exceed the reasonable costs of the investigation and
enforcement of the case
CONTROLLED SUBSTANCES I DANGEROUS DRUGS
12 Marijuana is a hallucinogenic Schedule I controlled substance as defined
in Health and Safety Code section 11054(d)(13) and a dangerous drug according to Business and
Professions Code section 4022
FIRST CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - Assault with a Firearm)
13 Respondent is subject to disciplinary action under section 4300490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1770 in that on or about July 1 2004 Respondent was
convicted of a crime substantially related to the qualifications functions or duties of a pharmacy
technician as follows
a On or about July 1 2004 in a criminal proceeding entitled The People of
the State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court Case
No2004014916FA Respondent was convicted on a plea of guilty for violating Penal Code
section 245( a)(2) (assault with a firearm) a felony and the special allegation of Penal Code
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section 12022S(a)(I) (use ofa firearm) a felony On or about August 30 2004 Respondent was
sentenced to serve five (5) years in the Department of Corrections
b The circumstances underlying the conviction are that on or about April 10
2004 Respondent was arrested after making violent andor death threats brandishing a Glock 40
caliber pistol and during a physical altercation shooting victim Michael M in the left shoulder
with the pistol
SECOND CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - DUI)
14 Respondent is subject to disciplinary action under section 4300 490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1770 in that on or about February 5 2003 Respondent
was convicted of a crime substantially related to the qualifications functions or duties of a
pharmacy technician as follows
a On or about February 5 2003 in a criminal proceeding entitled The
People ofthe State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court
Case No 2003001701 MA Respondent was convicted on a plea of guilty for violating Vehicle
Code section 23152b) (driving while having a 008 or higher blood alcohol content) a
misdemeanor
b The circumstances underlying the conviction are that on or about
January 52003 Respondent was arrested for driving under the influence of an alcoholic
beverage Respondents blood alcohol content tested at 013
TIDRD CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - Possession of Marijuana)
15 Respondent is subject to disciplinary action under section 4300 490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1710 in that on or about February 2 2000 Respondent
was convicted of a crime substantially related to the qualifications functions or duties of a
phatmacy technician as follows
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a On or about February 2 2000 in a criminal proceeding entitled The
People ofthe State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court
Case No 00M009643MA Respondent was convicted on a plea of guilty for violating Vehicle
code section 23222(b) (possession of marijuana in vehicle) a misdemeanor
b The circumstances underlying the conviction are that on or about
January 5 2000 Respondent was in possession of the controlled substance and dangerous drug
marijuana while driving a vehicle
FOURTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Possessions of Controlled Substance I Dangerous Drug - Marijuana)
16 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision 0) on the grounds of unprofessional conduct for violating section 4060 in that on or
about January 5 2000 Respondent was in possession of marijuana a controlled substance and
dangerous drug without a valid prescription
FIFTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Dishonest Acts)
17 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision (f) on the grounds of unprofessional conduct in that Respondent committed acts
involving moral turpitude dishonesty fraud deceit or corruption as set forth above in paragraphs
13 through 16 and incorporated herein by reference
SIXTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Acts Warranting Denial of Licensure)
18 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision (p) on the grounds of unprofessional conduct in conjunction with section 475
subdivisions (a)(2) (a)(3) and (a)(4) in that Respondent committed acts which would warrant
denial of licensure as set forth above in paragraphs 13 through 17 and incorporated herein by
reference
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PRAYER
WHEREFORE Complainant requests that a hearing be held on the matters herein
alleged and that following the hearing the Board of Pharmacy issue a decision
A Revoking or suspending Pharmacy Technician Registration No TCH
44940 issued to Christian Bevan Williams
B Ordering Christian Bevan Williams to pay the Board of Pharmacy the
reasonable costs of the investigation and enforcement of this case pursuant to Business and
Professions Code section 1253
C Taking such other and further action as deemed necessary and proper
DATED 10105
PATRICIAF HARRIS Executive Officer Board of Pharmacy Department of Consumer Affairs State of California
Complainant
7
DECLARATION OF SERVICE BY CERTIFIED MAIL AND FIRST CLASS MAIL (Separate Mailings)
Case Name In the Matter of the Accusation Against Christian Bevan Williams Case No 2871
I declare
I am employed in the Office of the Attorney General which is the office of a member of the California State Bar at which members direction this service is made I am 18 years of age or older and not a party to this matter I am familiar with the business practice at the Office of the Attorney General for collection and processing of correspondence for mailing with the United States Postal Service In accordance with that practice correspondence placed in the internal mail collection system at the Office of the Attorney General is deposited with the United States Postal Service that same day in the ordinary course ofbusiness
On November 30 2005 I served the attached Accusation Statement to Respondent Request for Discovery Notice of Defense and Government Code sections by placing a true copy thereof enclosed in a sealed envelope as certified mail with postage thereon fully prepaid and return receipt requested and another true copy of the Accusation Statement to Respondent Request for Discovery Notice of Defense and Government Code sections was enclosed in a second sealed envelope as first class mail with postage thereon fully prepaid in the internal mail collection system at the Office of the Attorney General at Los Angeles addressed as follows
Christian Bevan Williams 9 Poinsettia Gardens Drive Ventura CA 93004
Certified Mail Receipt No 7001 0360 0003 2701 4893
Christian Bevan Williams
Susan Cappello Enforcement Analyst Board of Pharmacy 400 R Street Suite 4070 Sacramento CA 95814-6200
=I CJ rshyru rn CJ CJ CJ
CJ D rn CJ
=I CJ CJ rshy
=I CJ rshyru rn Cl Cl Cl
Cl D rn Cl
r-=1 Cl Cl r-
Postmark HOl8 vs of the State of California the foregoing is tnle
ted on November 30 2005 at Los Angeles
Exhibit B
Postal Return Document
o Agent
o Addressee
D Is delivery address different from item 1 0 Yes
If YES enter delivery address below 0 No
~~lv0-wt)
Ace c~G~i-SENDER COMPLETE THIS SECTION
bull Complete items 1 2 and 3 Also complete item 4 if RestrictedDelivery is desired
bull Print your name and address on the reverse so that we can return the card to you
bull Attach this card to the back of the mail piece or on the front if space permits
1 Article Addressed to
Christian Bevan Villiams co Sierra Conservation Center Inmate Reg No V50004 PO Box 497 5100 O-Byrnes Ferry Road Jamestown CA 95327
3 Service Type
Ji( Certified Mail o Registered
o Insured Mail
Express Mail
COD
4 Restricted Delivery (Extra Fee) 0 Y
i Return Receipt for Merchandise
es
2 Article Number (Copy from service label) 7001 0360 0003 2701 4886
PS Form 3811 July 1999 Domestic Return Receipt 102595-00-M-0952
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respondents right to a hearing but the agency in its discretion may nevetihe1ess grant a hearing
8 Respondent failed to file a Notice of Defense within 15 days after service
upon him of the Accusation and therefore waived his right to a hearing on the merits of
Accusation No 2871
9 California Government Code section 11520 states in pertinent part
(a) If the respondent either fails to file a notice of defense or to appear at the
hearing the agency may take action based upon the respondents express admissions or upon
other evidence and affidavits may be used as evidence without any notice to respondent
10 Pursuant to its authority under Government Code section 11520 the Board
finds Respondent is in default The Board will take action without further hearing and based on
Respondents express admissions by way of default and the evidence before it contained in
Exhibits A and B finds that the allegations in Accusation No 2871 are true
11 The total costs for investigation and enforcement are $218250 as of
March 8 2006
DETERMINATION OF ISSUES
1 Based on the foregoing findings of fact Respondent Christian Bevan
Williams has subjected his Phatmacy Technician Registration No TCH 44940 to discipline
2 A copy of the Accusation is attached
3 The agency has jurisdiction to adjudicate this case by default
4 The Board of Pharmacy is authorized to revoke Respondents Pharmacy
Technician Registration based upon the following violations alleged in the Accusation
a Business and Professions Code sections 4301 subdivision (1) and 490
conviction(s) of substantially related crimes - assault with a firearm driving under the influence
and possession of marijuana
b Business and Professions Code sections 4301 subdivision (j) and 4060
possession of a controlled substance Marijuana
c Business and Professions Code sections 4301 subdivision (t) acts
involving moral turpitude dishonesty fraud deceit or corruption
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DECISION AND ORDER
IT IS SO ORDERED that Pharmacy Technician Registration No TCH 44940
heretofore issued to Respondent Christian Bevan Williams is revoked
Pursuant to Government Code section 11520 subdivision (c) Respondent may
serve a written motion requesting that the Decision be vacated and stating the grounds relied on
within seven (7) days after service of the Decision on Respondent The agency in its discretion
may vacate the Decision and grant a hearing on a showing of good cause as defined in the
statute
This Decision shall become effective on -LMa~y~34-1-1_200JJ-6-----shy
It is so ORDERED ~M(daYt--middot41-----2lLlOOu6L--_____
BOARD OF PHARMACY DEPARTMENT OF CONSUMERAFFAlRS STATE OF CALIFORNIA
By
Board President
Attachments Exhibit A Accusation No 2871 Exhibit B Postal retulTI document
60135522wpd
4
Exhibit A
Accusation No 2871
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BILL LOCKYER Attorney General of the State of California
JAMI L CANTORE State Bar No 165410 Deputy Attorney General
California Department of Justice 300 So Spring Street Suite 1702 Los Angeles CA 90013 Telephone (213) 897-2569 Facsimile (213) 897-2804
Attorneys for Complainant
BEFORE THE BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA
In the Matter of the Accusation Against
CHRISTIAN BEVAN WILLIAMS 9 Poinsettia Gardens Drive Ventura CA 93004
- andshy
co Sierra Conservation Center Inmate Reg No V50004 PO Box 497 5100 a-Byrnes Ferry Road Jamestown CA 95327
Pharmacy Technician Registration No TCH 44940
Respondent
Case No 2871
ACCUSATION
Complainant alleges
PARTIES
1 Patricia F Harris (Complainant) brings this Accusation solely in her
official capacity as the Executive Officer of the Board of Pharmacy Department of Consumer
Affairs (Board)
2 On or about October 222002 the Board issued Pharmacy Technician
Registration No TCH 44940 to Christian Bevan Williams (Respondent) On or about July 25
2005 pursuant to Business and Professions Code section 4311 subdivision (a) the Board issued
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a Notice ofAutomatic Suspension of License The Pharmacy Technician Registration will expire
on April 30 2006 unless renewed
JURISDICTION
3 This Accusation is brought before the Board under the authority of the
following laws All section references are to the Business and Professions Code unless otherwise
indicated
4 Section 4300 permits the Board to take disciplinary action to suspend or
revoke a license or permit
E Section 118 subdivision (b) provides that the suspension
expirationsurrendercancellation of a license shall not deprive the Board ofjurisdiction to
proceed with a disciplinary action during the period within which the license may be renewed
restored reissued or reinstated
F Section 490 states
A board may suspend or revoke a license on the ground that the licensee has been
convicted of a crime if the crime is substantially related to the qualifications functions or duties
of the business or profession for which the license was issued A conviction within the meaning
of this section means a plea or verdict of guilty or a conviction following a plea of nolo
contendere Any action which a board is permitted to take following the establishment of a
conviction may be taken when the time for appeal has elapsed or the judgment of conviction has
been affinned on appeal or when an order granting probation is made suspending the imposition
of sentence irrespective of a subsequent order under the provisions of Section 12034 of the
Penal Code
7 Section 4301 states in pertinent part
The board shall take action against any holder of a license who is guilty of
unprofessional conduct or whose license has been procured by fraud or misrepresentation or
issued by mistake Unprofessional conduct shall include but is not limited to any of the
following
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(f) The commission of any act involving moral turpitude dishonesty fraud
deceit or corruption whether the act is committed in the course of relations as a licensee or
otherwise and whether the act is a felony or misdemeanor or not
0) The violation of any of the statutes of this state or of the United States
regulating controlled substances and dangerous drugs
n(l) The conviction of a crime substantially related to the qualifications functions
and duties of a licensee under this chapter The record of conviction shall be conclusive
evidence only of the fact that the conviction occurred
nco) Violating or attempting to violate directly or indirectly or assisting in or
abetting the violation of or conspiring to violate any provision or term of this chapter or of the
applicable federal and state laws and regulations governing pharmacy including regulations
established by the board
(p) Actions or conduct that would have warranted denial of a license
8 Section 4060 states in pertinent part that [n]o person shall possess any
controlled substance except that furnished to a person upon the prescription of a physician
dentist podiatrist or veterinarian or furnished pursuant to a drug order issued by a certified
nurse-midwife pursuant to Section 274651 a nurse practitioner pursuant to Section 28361 or a
physician assistant pursuant to Section 35021
9 California Code of Regulations title 16 section 1770 states
For the purpose of denial suspension or revocation of a personal or facility
license pursuant to Division 15 (commencing with Section 475) of the Business and Professions
Code a crime or act shall be considered substantially related to the qualifications functions or
duties of a licensee or registrant if to a substantial degree it evidences present or potential
unfitness of a licensee or registrant to perform the functions authorized by his license or
registration in a manner consistent with the public health safety or welfare
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10 Section 475 states in pertinent part
(a) Notwithstanding any other provisions of this code the provisions of this
division shall govern the denial of licenses on the grounds of
(2) Conviction of a crime
(3) Commission of any act involving dishonesty fraud or deceit with the intent
to substantially benefit himself or another or substantially injure another
(4) Commission of any act which if done by a licentiate of the business or
profession inquestion would be grounds for suspension or revocation of license
11 Section 1253 states in pertinent part that the Board may request the
administrative law judge to direct a licentiate found to have committed a violation or violations
of the licensing act to pay a sum not to exceed the reasonable costs of the investigation and
enforcement of the case
CONTROLLED SUBSTANCES I DANGEROUS DRUGS
12 Marijuana is a hallucinogenic Schedule I controlled substance as defined
in Health and Safety Code section 11054(d)(13) and a dangerous drug according to Business and
Professions Code section 4022
FIRST CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - Assault with a Firearm)
13 Respondent is subject to disciplinary action under section 4300490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1770 in that on or about July 1 2004 Respondent was
convicted of a crime substantially related to the qualifications functions or duties of a pharmacy
technician as follows
a On or about July 1 2004 in a criminal proceeding entitled The People of
the State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court Case
No2004014916FA Respondent was convicted on a plea of guilty for violating Penal Code
section 245( a)(2) (assault with a firearm) a felony and the special allegation of Penal Code
4
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section 12022S(a)(I) (use ofa firearm) a felony On or about August 30 2004 Respondent was
sentenced to serve five (5) years in the Department of Corrections
b The circumstances underlying the conviction are that on or about April 10
2004 Respondent was arrested after making violent andor death threats brandishing a Glock 40
caliber pistol and during a physical altercation shooting victim Michael M in the left shoulder
with the pistol
SECOND CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - DUI)
14 Respondent is subject to disciplinary action under section 4300 490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1770 in that on or about February 5 2003 Respondent
was convicted of a crime substantially related to the qualifications functions or duties of a
pharmacy technician as follows
a On or about February 5 2003 in a criminal proceeding entitled The
People ofthe State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court
Case No 2003001701 MA Respondent was convicted on a plea of guilty for violating Vehicle
Code section 23152b) (driving while having a 008 or higher blood alcohol content) a
misdemeanor
b The circumstances underlying the conviction are that on or about
January 52003 Respondent was arrested for driving under the influence of an alcoholic
beverage Respondents blood alcohol content tested at 013
TIDRD CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - Possession of Marijuana)
15 Respondent is subject to disciplinary action under section 4300 490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1710 in that on or about February 2 2000 Respondent
was convicted of a crime substantially related to the qualifications functions or duties of a
phatmacy technician as follows
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a On or about February 2 2000 in a criminal proceeding entitled The
People ofthe State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court
Case No 00M009643MA Respondent was convicted on a plea of guilty for violating Vehicle
code section 23222(b) (possession of marijuana in vehicle) a misdemeanor
b The circumstances underlying the conviction are that on or about
January 5 2000 Respondent was in possession of the controlled substance and dangerous drug
marijuana while driving a vehicle
FOURTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Possessions of Controlled Substance I Dangerous Drug - Marijuana)
16 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision 0) on the grounds of unprofessional conduct for violating section 4060 in that on or
about January 5 2000 Respondent was in possession of marijuana a controlled substance and
dangerous drug without a valid prescription
FIFTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Dishonest Acts)
17 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision (f) on the grounds of unprofessional conduct in that Respondent committed acts
involving moral turpitude dishonesty fraud deceit or corruption as set forth above in paragraphs
13 through 16 and incorporated herein by reference
SIXTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Acts Warranting Denial of Licensure)
18 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision (p) on the grounds of unprofessional conduct in conjunction with section 475
subdivisions (a)(2) (a)(3) and (a)(4) in that Respondent committed acts which would warrant
denial of licensure as set forth above in paragraphs 13 through 17 and incorporated herein by
reference
I I I
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PRAYER
WHEREFORE Complainant requests that a hearing be held on the matters herein
alleged and that following the hearing the Board of Pharmacy issue a decision
A Revoking or suspending Pharmacy Technician Registration No TCH
44940 issued to Christian Bevan Williams
B Ordering Christian Bevan Williams to pay the Board of Pharmacy the
reasonable costs of the investigation and enforcement of this case pursuant to Business and
Professions Code section 1253
C Taking such other and further action as deemed necessary and proper
DATED 10105
PATRICIAF HARRIS Executive Officer Board of Pharmacy Department of Consumer Affairs State of California
Complainant
7
DECLARATION OF SERVICE BY CERTIFIED MAIL AND FIRST CLASS MAIL (Separate Mailings)
Case Name In the Matter of the Accusation Against Christian Bevan Williams Case No 2871
I declare
I am employed in the Office of the Attorney General which is the office of a member of the California State Bar at which members direction this service is made I am 18 years of age or older and not a party to this matter I am familiar with the business practice at the Office of the Attorney General for collection and processing of correspondence for mailing with the United States Postal Service In accordance with that practice correspondence placed in the internal mail collection system at the Office of the Attorney General is deposited with the United States Postal Service that same day in the ordinary course ofbusiness
On November 30 2005 I served the attached Accusation Statement to Respondent Request for Discovery Notice of Defense and Government Code sections by placing a true copy thereof enclosed in a sealed envelope as certified mail with postage thereon fully prepaid and return receipt requested and another true copy of the Accusation Statement to Respondent Request for Discovery Notice of Defense and Government Code sections was enclosed in a second sealed envelope as first class mail with postage thereon fully prepaid in the internal mail collection system at the Office of the Attorney General at Los Angeles addressed as follows
Christian Bevan Williams 9 Poinsettia Gardens Drive Ventura CA 93004
Certified Mail Receipt No 7001 0360 0003 2701 4893
Christian Bevan Williams
Susan Cappello Enforcement Analyst Board of Pharmacy 400 R Street Suite 4070 Sacramento CA 95814-6200
=I CJ rshyru rn CJ CJ CJ
CJ D rn CJ
=I CJ CJ rshy
=I CJ rshyru rn Cl Cl Cl
Cl D rn Cl
r-=1 Cl Cl r-
Postmark HOl8 vs of the State of California the foregoing is tnle
ted on November 30 2005 at Los Angeles
Exhibit B
Postal Return Document
o Agent
o Addressee
D Is delivery address different from item 1 0 Yes
If YES enter delivery address below 0 No
~~lv0-wt)
Ace c~G~i-SENDER COMPLETE THIS SECTION
bull Complete items 1 2 and 3 Also complete item 4 if RestrictedDelivery is desired
bull Print your name and address on the reverse so that we can return the card to you
bull Attach this card to the back of the mail piece or on the front if space permits
1 Article Addressed to
Christian Bevan Villiams co Sierra Conservation Center Inmate Reg No V50004 PO Box 497 5100 O-Byrnes Ferry Road Jamestown CA 95327
3 Service Type
Ji( Certified Mail o Registered
o Insured Mail
Express Mail
COD
4 Restricted Delivery (Extra Fee) 0 Y
i Return Receipt for Merchandise
es
2 Article Number (Copy from service label) 7001 0360 0003 2701 4886
PS Form 3811 July 1999 Domestic Return Receipt 102595-00-M-0952
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DECISION AND ORDER
IT IS SO ORDERED that Pharmacy Technician Registration No TCH 44940
heretofore issued to Respondent Christian Bevan Williams is revoked
Pursuant to Government Code section 11520 subdivision (c) Respondent may
serve a written motion requesting that the Decision be vacated and stating the grounds relied on
within seven (7) days after service of the Decision on Respondent The agency in its discretion
may vacate the Decision and grant a hearing on a showing of good cause as defined in the
statute
This Decision shall become effective on -LMa~y~34-1-1_200JJ-6-----shy
It is so ORDERED ~M(daYt--middot41-----2lLlOOu6L--_____
BOARD OF PHARMACY DEPARTMENT OF CONSUMERAFFAlRS STATE OF CALIFORNIA
By
Board President
Attachments Exhibit A Accusation No 2871 Exhibit B Postal retulTI document
60135522wpd
4
Exhibit A
Accusation No 2871
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BILL LOCKYER Attorney General of the State of California
JAMI L CANTORE State Bar No 165410 Deputy Attorney General
California Department of Justice 300 So Spring Street Suite 1702 Los Angeles CA 90013 Telephone (213) 897-2569 Facsimile (213) 897-2804
Attorneys for Complainant
BEFORE THE BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA
In the Matter of the Accusation Against
CHRISTIAN BEVAN WILLIAMS 9 Poinsettia Gardens Drive Ventura CA 93004
- andshy
co Sierra Conservation Center Inmate Reg No V50004 PO Box 497 5100 a-Byrnes Ferry Road Jamestown CA 95327
Pharmacy Technician Registration No TCH 44940
Respondent
Case No 2871
ACCUSATION
Complainant alleges
PARTIES
1 Patricia F Harris (Complainant) brings this Accusation solely in her
official capacity as the Executive Officer of the Board of Pharmacy Department of Consumer
Affairs (Board)
2 On or about October 222002 the Board issued Pharmacy Technician
Registration No TCH 44940 to Christian Bevan Williams (Respondent) On or about July 25
2005 pursuant to Business and Professions Code section 4311 subdivision (a) the Board issued
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a Notice ofAutomatic Suspension of License The Pharmacy Technician Registration will expire
on April 30 2006 unless renewed
JURISDICTION
3 This Accusation is brought before the Board under the authority of the
following laws All section references are to the Business and Professions Code unless otherwise
indicated
4 Section 4300 permits the Board to take disciplinary action to suspend or
revoke a license or permit
E Section 118 subdivision (b) provides that the suspension
expirationsurrendercancellation of a license shall not deprive the Board ofjurisdiction to
proceed with a disciplinary action during the period within which the license may be renewed
restored reissued or reinstated
F Section 490 states
A board may suspend or revoke a license on the ground that the licensee has been
convicted of a crime if the crime is substantially related to the qualifications functions or duties
of the business or profession for which the license was issued A conviction within the meaning
of this section means a plea or verdict of guilty or a conviction following a plea of nolo
contendere Any action which a board is permitted to take following the establishment of a
conviction may be taken when the time for appeal has elapsed or the judgment of conviction has
been affinned on appeal or when an order granting probation is made suspending the imposition
of sentence irrespective of a subsequent order under the provisions of Section 12034 of the
Penal Code
7 Section 4301 states in pertinent part
The board shall take action against any holder of a license who is guilty of
unprofessional conduct or whose license has been procured by fraud or misrepresentation or
issued by mistake Unprofessional conduct shall include but is not limited to any of the
following
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(f) The commission of any act involving moral turpitude dishonesty fraud
deceit or corruption whether the act is committed in the course of relations as a licensee or
otherwise and whether the act is a felony or misdemeanor or not
0) The violation of any of the statutes of this state or of the United States
regulating controlled substances and dangerous drugs
n(l) The conviction of a crime substantially related to the qualifications functions
and duties of a licensee under this chapter The record of conviction shall be conclusive
evidence only of the fact that the conviction occurred
nco) Violating or attempting to violate directly or indirectly or assisting in or
abetting the violation of or conspiring to violate any provision or term of this chapter or of the
applicable federal and state laws and regulations governing pharmacy including regulations
established by the board
(p) Actions or conduct that would have warranted denial of a license
8 Section 4060 states in pertinent part that [n]o person shall possess any
controlled substance except that furnished to a person upon the prescription of a physician
dentist podiatrist or veterinarian or furnished pursuant to a drug order issued by a certified
nurse-midwife pursuant to Section 274651 a nurse practitioner pursuant to Section 28361 or a
physician assistant pursuant to Section 35021
9 California Code of Regulations title 16 section 1770 states
For the purpose of denial suspension or revocation of a personal or facility
license pursuant to Division 15 (commencing with Section 475) of the Business and Professions
Code a crime or act shall be considered substantially related to the qualifications functions or
duties of a licensee or registrant if to a substantial degree it evidences present or potential
unfitness of a licensee or registrant to perform the functions authorized by his license or
registration in a manner consistent with the public health safety or welfare
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10 Section 475 states in pertinent part
(a) Notwithstanding any other provisions of this code the provisions of this
division shall govern the denial of licenses on the grounds of
(2) Conviction of a crime
(3) Commission of any act involving dishonesty fraud or deceit with the intent
to substantially benefit himself or another or substantially injure another
(4) Commission of any act which if done by a licentiate of the business or
profession inquestion would be grounds for suspension or revocation of license
11 Section 1253 states in pertinent part that the Board may request the
administrative law judge to direct a licentiate found to have committed a violation or violations
of the licensing act to pay a sum not to exceed the reasonable costs of the investigation and
enforcement of the case
CONTROLLED SUBSTANCES I DANGEROUS DRUGS
12 Marijuana is a hallucinogenic Schedule I controlled substance as defined
in Health and Safety Code section 11054(d)(13) and a dangerous drug according to Business and
Professions Code section 4022
FIRST CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - Assault with a Firearm)
13 Respondent is subject to disciplinary action under section 4300490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1770 in that on or about July 1 2004 Respondent was
convicted of a crime substantially related to the qualifications functions or duties of a pharmacy
technician as follows
a On or about July 1 2004 in a criminal proceeding entitled The People of
the State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court Case
No2004014916FA Respondent was convicted on a plea of guilty for violating Penal Code
section 245( a)(2) (assault with a firearm) a felony and the special allegation of Penal Code
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section 12022S(a)(I) (use ofa firearm) a felony On or about August 30 2004 Respondent was
sentenced to serve five (5) years in the Department of Corrections
b The circumstances underlying the conviction are that on or about April 10
2004 Respondent was arrested after making violent andor death threats brandishing a Glock 40
caliber pistol and during a physical altercation shooting victim Michael M in the left shoulder
with the pistol
SECOND CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - DUI)
14 Respondent is subject to disciplinary action under section 4300 490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1770 in that on or about February 5 2003 Respondent
was convicted of a crime substantially related to the qualifications functions or duties of a
pharmacy technician as follows
a On or about February 5 2003 in a criminal proceeding entitled The
People ofthe State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court
Case No 2003001701 MA Respondent was convicted on a plea of guilty for violating Vehicle
Code section 23152b) (driving while having a 008 or higher blood alcohol content) a
misdemeanor
b The circumstances underlying the conviction are that on or about
January 52003 Respondent was arrested for driving under the influence of an alcoholic
beverage Respondents blood alcohol content tested at 013
TIDRD CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - Possession of Marijuana)
15 Respondent is subject to disciplinary action under section 4300 490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1710 in that on or about February 2 2000 Respondent
was convicted of a crime substantially related to the qualifications functions or duties of a
phatmacy technician as follows
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a On or about February 2 2000 in a criminal proceeding entitled The
People ofthe State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court
Case No 00M009643MA Respondent was convicted on a plea of guilty for violating Vehicle
code section 23222(b) (possession of marijuana in vehicle) a misdemeanor
b The circumstances underlying the conviction are that on or about
January 5 2000 Respondent was in possession of the controlled substance and dangerous drug
marijuana while driving a vehicle
FOURTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Possessions of Controlled Substance I Dangerous Drug - Marijuana)
16 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision 0) on the grounds of unprofessional conduct for violating section 4060 in that on or
about January 5 2000 Respondent was in possession of marijuana a controlled substance and
dangerous drug without a valid prescription
FIFTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Dishonest Acts)
17 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision (f) on the grounds of unprofessional conduct in that Respondent committed acts
involving moral turpitude dishonesty fraud deceit or corruption as set forth above in paragraphs
13 through 16 and incorporated herein by reference
SIXTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Acts Warranting Denial of Licensure)
18 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision (p) on the grounds of unprofessional conduct in conjunction with section 475
subdivisions (a)(2) (a)(3) and (a)(4) in that Respondent committed acts which would warrant
denial of licensure as set forth above in paragraphs 13 through 17 and incorporated herein by
reference
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PRAYER
WHEREFORE Complainant requests that a hearing be held on the matters herein
alleged and that following the hearing the Board of Pharmacy issue a decision
A Revoking or suspending Pharmacy Technician Registration No TCH
44940 issued to Christian Bevan Williams
B Ordering Christian Bevan Williams to pay the Board of Pharmacy the
reasonable costs of the investigation and enforcement of this case pursuant to Business and
Professions Code section 1253
C Taking such other and further action as deemed necessary and proper
DATED 10105
PATRICIAF HARRIS Executive Officer Board of Pharmacy Department of Consumer Affairs State of California
Complainant
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DECLARATION OF SERVICE BY CERTIFIED MAIL AND FIRST CLASS MAIL (Separate Mailings)
Case Name In the Matter of the Accusation Against Christian Bevan Williams Case No 2871
I declare
I am employed in the Office of the Attorney General which is the office of a member of the California State Bar at which members direction this service is made I am 18 years of age or older and not a party to this matter I am familiar with the business practice at the Office of the Attorney General for collection and processing of correspondence for mailing with the United States Postal Service In accordance with that practice correspondence placed in the internal mail collection system at the Office of the Attorney General is deposited with the United States Postal Service that same day in the ordinary course ofbusiness
On November 30 2005 I served the attached Accusation Statement to Respondent Request for Discovery Notice of Defense and Government Code sections by placing a true copy thereof enclosed in a sealed envelope as certified mail with postage thereon fully prepaid and return receipt requested and another true copy of the Accusation Statement to Respondent Request for Discovery Notice of Defense and Government Code sections was enclosed in a second sealed envelope as first class mail with postage thereon fully prepaid in the internal mail collection system at the Office of the Attorney General at Los Angeles addressed as follows
Christian Bevan Williams 9 Poinsettia Gardens Drive Ventura CA 93004
Certified Mail Receipt No 7001 0360 0003 2701 4893
Christian Bevan Williams
Susan Cappello Enforcement Analyst Board of Pharmacy 400 R Street Suite 4070 Sacramento CA 95814-6200
=I CJ rshyru rn CJ CJ CJ
CJ D rn CJ
=I CJ CJ rshy
=I CJ rshyru rn Cl Cl Cl
Cl D rn Cl
r-=1 Cl Cl r-
Postmark HOl8 vs of the State of California the foregoing is tnle
ted on November 30 2005 at Los Angeles
Exhibit B
Postal Return Document
o Agent
o Addressee
D Is delivery address different from item 1 0 Yes
If YES enter delivery address below 0 No
~~lv0-wt)
Ace c~G~i-SENDER COMPLETE THIS SECTION
bull Complete items 1 2 and 3 Also complete item 4 if RestrictedDelivery is desired
bull Print your name and address on the reverse so that we can return the card to you
bull Attach this card to the back of the mail piece or on the front if space permits
1 Article Addressed to
Christian Bevan Villiams co Sierra Conservation Center Inmate Reg No V50004 PO Box 497 5100 O-Byrnes Ferry Road Jamestown CA 95327
3 Service Type
Ji( Certified Mail o Registered
o Insured Mail
Express Mail
COD
4 Restricted Delivery (Extra Fee) 0 Y
i Return Receipt for Merchandise
es
2 Article Number (Copy from service label) 7001 0360 0003 2701 4886
PS Form 3811 July 1999 Domestic Return Receipt 102595-00-M-0952
Exhibit A
Accusation No 2871
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BILL LOCKYER Attorney General of the State of California
JAMI L CANTORE State Bar No 165410 Deputy Attorney General
California Department of Justice 300 So Spring Street Suite 1702 Los Angeles CA 90013 Telephone (213) 897-2569 Facsimile (213) 897-2804
Attorneys for Complainant
BEFORE THE BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA
In the Matter of the Accusation Against
CHRISTIAN BEVAN WILLIAMS 9 Poinsettia Gardens Drive Ventura CA 93004
- andshy
co Sierra Conservation Center Inmate Reg No V50004 PO Box 497 5100 a-Byrnes Ferry Road Jamestown CA 95327
Pharmacy Technician Registration No TCH 44940
Respondent
Case No 2871
ACCUSATION
Complainant alleges
PARTIES
1 Patricia F Harris (Complainant) brings this Accusation solely in her
official capacity as the Executive Officer of the Board of Pharmacy Department of Consumer
Affairs (Board)
2 On or about October 222002 the Board issued Pharmacy Technician
Registration No TCH 44940 to Christian Bevan Williams (Respondent) On or about July 25
2005 pursuant to Business and Professions Code section 4311 subdivision (a) the Board issued
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a Notice ofAutomatic Suspension of License The Pharmacy Technician Registration will expire
on April 30 2006 unless renewed
JURISDICTION
3 This Accusation is brought before the Board under the authority of the
following laws All section references are to the Business and Professions Code unless otherwise
indicated
4 Section 4300 permits the Board to take disciplinary action to suspend or
revoke a license or permit
E Section 118 subdivision (b) provides that the suspension
expirationsurrendercancellation of a license shall not deprive the Board ofjurisdiction to
proceed with a disciplinary action during the period within which the license may be renewed
restored reissued or reinstated
F Section 490 states
A board may suspend or revoke a license on the ground that the licensee has been
convicted of a crime if the crime is substantially related to the qualifications functions or duties
of the business or profession for which the license was issued A conviction within the meaning
of this section means a plea or verdict of guilty or a conviction following a plea of nolo
contendere Any action which a board is permitted to take following the establishment of a
conviction may be taken when the time for appeal has elapsed or the judgment of conviction has
been affinned on appeal or when an order granting probation is made suspending the imposition
of sentence irrespective of a subsequent order under the provisions of Section 12034 of the
Penal Code
7 Section 4301 states in pertinent part
The board shall take action against any holder of a license who is guilty of
unprofessional conduct or whose license has been procured by fraud or misrepresentation or
issued by mistake Unprofessional conduct shall include but is not limited to any of the
following
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(f) The commission of any act involving moral turpitude dishonesty fraud
deceit or corruption whether the act is committed in the course of relations as a licensee or
otherwise and whether the act is a felony or misdemeanor or not
0) The violation of any of the statutes of this state or of the United States
regulating controlled substances and dangerous drugs
n(l) The conviction of a crime substantially related to the qualifications functions
and duties of a licensee under this chapter The record of conviction shall be conclusive
evidence only of the fact that the conviction occurred
nco) Violating or attempting to violate directly or indirectly or assisting in or
abetting the violation of or conspiring to violate any provision or term of this chapter or of the
applicable federal and state laws and regulations governing pharmacy including regulations
established by the board
(p) Actions or conduct that would have warranted denial of a license
8 Section 4060 states in pertinent part that [n]o person shall possess any
controlled substance except that furnished to a person upon the prescription of a physician
dentist podiatrist or veterinarian or furnished pursuant to a drug order issued by a certified
nurse-midwife pursuant to Section 274651 a nurse practitioner pursuant to Section 28361 or a
physician assistant pursuant to Section 35021
9 California Code of Regulations title 16 section 1770 states
For the purpose of denial suspension or revocation of a personal or facility
license pursuant to Division 15 (commencing with Section 475) of the Business and Professions
Code a crime or act shall be considered substantially related to the qualifications functions or
duties of a licensee or registrant if to a substantial degree it evidences present or potential
unfitness of a licensee or registrant to perform the functions authorized by his license or
registration in a manner consistent with the public health safety or welfare
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10 Section 475 states in pertinent part
(a) Notwithstanding any other provisions of this code the provisions of this
division shall govern the denial of licenses on the grounds of
(2) Conviction of a crime
(3) Commission of any act involving dishonesty fraud or deceit with the intent
to substantially benefit himself or another or substantially injure another
(4) Commission of any act which if done by a licentiate of the business or
profession inquestion would be grounds for suspension or revocation of license
11 Section 1253 states in pertinent part that the Board may request the
administrative law judge to direct a licentiate found to have committed a violation or violations
of the licensing act to pay a sum not to exceed the reasonable costs of the investigation and
enforcement of the case
CONTROLLED SUBSTANCES I DANGEROUS DRUGS
12 Marijuana is a hallucinogenic Schedule I controlled substance as defined
in Health and Safety Code section 11054(d)(13) and a dangerous drug according to Business and
Professions Code section 4022
FIRST CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - Assault with a Firearm)
13 Respondent is subject to disciplinary action under section 4300490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1770 in that on or about July 1 2004 Respondent was
convicted of a crime substantially related to the qualifications functions or duties of a pharmacy
technician as follows
a On or about July 1 2004 in a criminal proceeding entitled The People of
the State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court Case
No2004014916FA Respondent was convicted on a plea of guilty for violating Penal Code
section 245( a)(2) (assault with a firearm) a felony and the special allegation of Penal Code
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section 12022S(a)(I) (use ofa firearm) a felony On or about August 30 2004 Respondent was
sentenced to serve five (5) years in the Department of Corrections
b The circumstances underlying the conviction are that on or about April 10
2004 Respondent was arrested after making violent andor death threats brandishing a Glock 40
caliber pistol and during a physical altercation shooting victim Michael M in the left shoulder
with the pistol
SECOND CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - DUI)
14 Respondent is subject to disciplinary action under section 4300 490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1770 in that on or about February 5 2003 Respondent
was convicted of a crime substantially related to the qualifications functions or duties of a
pharmacy technician as follows
a On or about February 5 2003 in a criminal proceeding entitled The
People ofthe State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court
Case No 2003001701 MA Respondent was convicted on a plea of guilty for violating Vehicle
Code section 23152b) (driving while having a 008 or higher blood alcohol content) a
misdemeanor
b The circumstances underlying the conviction are that on or about
January 52003 Respondent was arrested for driving under the influence of an alcoholic
beverage Respondents blood alcohol content tested at 013
TIDRD CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - Possession of Marijuana)
15 Respondent is subject to disciplinary action under section 4300 490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1710 in that on or about February 2 2000 Respondent
was convicted of a crime substantially related to the qualifications functions or duties of a
phatmacy technician as follows
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a On or about February 2 2000 in a criminal proceeding entitled The
People ofthe State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court
Case No 00M009643MA Respondent was convicted on a plea of guilty for violating Vehicle
code section 23222(b) (possession of marijuana in vehicle) a misdemeanor
b The circumstances underlying the conviction are that on or about
January 5 2000 Respondent was in possession of the controlled substance and dangerous drug
marijuana while driving a vehicle
FOURTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Possessions of Controlled Substance I Dangerous Drug - Marijuana)
16 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision 0) on the grounds of unprofessional conduct for violating section 4060 in that on or
about January 5 2000 Respondent was in possession of marijuana a controlled substance and
dangerous drug without a valid prescription
FIFTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Dishonest Acts)
17 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision (f) on the grounds of unprofessional conduct in that Respondent committed acts
involving moral turpitude dishonesty fraud deceit or corruption as set forth above in paragraphs
13 through 16 and incorporated herein by reference
SIXTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Acts Warranting Denial of Licensure)
18 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision (p) on the grounds of unprofessional conduct in conjunction with section 475
subdivisions (a)(2) (a)(3) and (a)(4) in that Respondent committed acts which would warrant
denial of licensure as set forth above in paragraphs 13 through 17 and incorporated herein by
reference
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PRAYER
WHEREFORE Complainant requests that a hearing be held on the matters herein
alleged and that following the hearing the Board of Pharmacy issue a decision
A Revoking or suspending Pharmacy Technician Registration No TCH
44940 issued to Christian Bevan Williams
B Ordering Christian Bevan Williams to pay the Board of Pharmacy the
reasonable costs of the investigation and enforcement of this case pursuant to Business and
Professions Code section 1253
C Taking such other and further action as deemed necessary and proper
DATED 10105
PATRICIAF HARRIS Executive Officer Board of Pharmacy Department of Consumer Affairs State of California
Complainant
7
DECLARATION OF SERVICE BY CERTIFIED MAIL AND FIRST CLASS MAIL (Separate Mailings)
Case Name In the Matter of the Accusation Against Christian Bevan Williams Case No 2871
I declare
I am employed in the Office of the Attorney General which is the office of a member of the California State Bar at which members direction this service is made I am 18 years of age or older and not a party to this matter I am familiar with the business practice at the Office of the Attorney General for collection and processing of correspondence for mailing with the United States Postal Service In accordance with that practice correspondence placed in the internal mail collection system at the Office of the Attorney General is deposited with the United States Postal Service that same day in the ordinary course ofbusiness
On November 30 2005 I served the attached Accusation Statement to Respondent Request for Discovery Notice of Defense and Government Code sections by placing a true copy thereof enclosed in a sealed envelope as certified mail with postage thereon fully prepaid and return receipt requested and another true copy of the Accusation Statement to Respondent Request for Discovery Notice of Defense and Government Code sections was enclosed in a second sealed envelope as first class mail with postage thereon fully prepaid in the internal mail collection system at the Office of the Attorney General at Los Angeles addressed as follows
Christian Bevan Williams 9 Poinsettia Gardens Drive Ventura CA 93004
Certified Mail Receipt No 7001 0360 0003 2701 4893
Christian Bevan Williams
Susan Cappello Enforcement Analyst Board of Pharmacy 400 R Street Suite 4070 Sacramento CA 95814-6200
=I CJ rshyru rn CJ CJ CJ
CJ D rn CJ
=I CJ CJ rshy
=I CJ rshyru rn Cl Cl Cl
Cl D rn Cl
r-=1 Cl Cl r-
Postmark HOl8 vs of the State of California the foregoing is tnle
ted on November 30 2005 at Los Angeles
Exhibit B
Postal Return Document
o Agent
o Addressee
D Is delivery address different from item 1 0 Yes
If YES enter delivery address below 0 No
~~lv0-wt)
Ace c~G~i-SENDER COMPLETE THIS SECTION
bull Complete items 1 2 and 3 Also complete item 4 if RestrictedDelivery is desired
bull Print your name and address on the reverse so that we can return the card to you
bull Attach this card to the back of the mail piece or on the front if space permits
1 Article Addressed to
Christian Bevan Villiams co Sierra Conservation Center Inmate Reg No V50004 PO Box 497 5100 O-Byrnes Ferry Road Jamestown CA 95327
3 Service Type
Ji( Certified Mail o Registered
o Insured Mail
Express Mail
COD
4 Restricted Delivery (Extra Fee) 0 Y
i Return Receipt for Merchandise
es
2 Article Number (Copy from service label) 7001 0360 0003 2701 4886
PS Form 3811 July 1999 Domestic Return Receipt 102595-00-M-0952
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BILL LOCKYER Attorney General of the State of California
JAMI L CANTORE State Bar No 165410 Deputy Attorney General
California Department of Justice 300 So Spring Street Suite 1702 Los Angeles CA 90013 Telephone (213) 897-2569 Facsimile (213) 897-2804
Attorneys for Complainant
BEFORE THE BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA
In the Matter of the Accusation Against
CHRISTIAN BEVAN WILLIAMS 9 Poinsettia Gardens Drive Ventura CA 93004
- andshy
co Sierra Conservation Center Inmate Reg No V50004 PO Box 497 5100 a-Byrnes Ferry Road Jamestown CA 95327
Pharmacy Technician Registration No TCH 44940
Respondent
Case No 2871
ACCUSATION
Complainant alleges
PARTIES
1 Patricia F Harris (Complainant) brings this Accusation solely in her
official capacity as the Executive Officer of the Board of Pharmacy Department of Consumer
Affairs (Board)
2 On or about October 222002 the Board issued Pharmacy Technician
Registration No TCH 44940 to Christian Bevan Williams (Respondent) On or about July 25
2005 pursuant to Business and Professions Code section 4311 subdivision (a) the Board issued
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a Notice ofAutomatic Suspension of License The Pharmacy Technician Registration will expire
on April 30 2006 unless renewed
JURISDICTION
3 This Accusation is brought before the Board under the authority of the
following laws All section references are to the Business and Professions Code unless otherwise
indicated
4 Section 4300 permits the Board to take disciplinary action to suspend or
revoke a license or permit
E Section 118 subdivision (b) provides that the suspension
expirationsurrendercancellation of a license shall not deprive the Board ofjurisdiction to
proceed with a disciplinary action during the period within which the license may be renewed
restored reissued or reinstated
F Section 490 states
A board may suspend or revoke a license on the ground that the licensee has been
convicted of a crime if the crime is substantially related to the qualifications functions or duties
of the business or profession for which the license was issued A conviction within the meaning
of this section means a plea or verdict of guilty or a conviction following a plea of nolo
contendere Any action which a board is permitted to take following the establishment of a
conviction may be taken when the time for appeal has elapsed or the judgment of conviction has
been affinned on appeal or when an order granting probation is made suspending the imposition
of sentence irrespective of a subsequent order under the provisions of Section 12034 of the
Penal Code
7 Section 4301 states in pertinent part
The board shall take action against any holder of a license who is guilty of
unprofessional conduct or whose license has been procured by fraud or misrepresentation or
issued by mistake Unprofessional conduct shall include but is not limited to any of the
following
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(f) The commission of any act involving moral turpitude dishonesty fraud
deceit or corruption whether the act is committed in the course of relations as a licensee or
otherwise and whether the act is a felony or misdemeanor or not
0) The violation of any of the statutes of this state or of the United States
regulating controlled substances and dangerous drugs
n(l) The conviction of a crime substantially related to the qualifications functions
and duties of a licensee under this chapter The record of conviction shall be conclusive
evidence only of the fact that the conviction occurred
nco) Violating or attempting to violate directly or indirectly or assisting in or
abetting the violation of or conspiring to violate any provision or term of this chapter or of the
applicable federal and state laws and regulations governing pharmacy including regulations
established by the board
(p) Actions or conduct that would have warranted denial of a license
8 Section 4060 states in pertinent part that [n]o person shall possess any
controlled substance except that furnished to a person upon the prescription of a physician
dentist podiatrist or veterinarian or furnished pursuant to a drug order issued by a certified
nurse-midwife pursuant to Section 274651 a nurse practitioner pursuant to Section 28361 or a
physician assistant pursuant to Section 35021
9 California Code of Regulations title 16 section 1770 states
For the purpose of denial suspension or revocation of a personal or facility
license pursuant to Division 15 (commencing with Section 475) of the Business and Professions
Code a crime or act shall be considered substantially related to the qualifications functions or
duties of a licensee or registrant if to a substantial degree it evidences present or potential
unfitness of a licensee or registrant to perform the functions authorized by his license or
registration in a manner consistent with the public health safety or welfare
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10 Section 475 states in pertinent part
(a) Notwithstanding any other provisions of this code the provisions of this
division shall govern the denial of licenses on the grounds of
(2) Conviction of a crime
(3) Commission of any act involving dishonesty fraud or deceit with the intent
to substantially benefit himself or another or substantially injure another
(4) Commission of any act which if done by a licentiate of the business or
profession inquestion would be grounds for suspension or revocation of license
11 Section 1253 states in pertinent part that the Board may request the
administrative law judge to direct a licentiate found to have committed a violation or violations
of the licensing act to pay a sum not to exceed the reasonable costs of the investigation and
enforcement of the case
CONTROLLED SUBSTANCES I DANGEROUS DRUGS
12 Marijuana is a hallucinogenic Schedule I controlled substance as defined
in Health and Safety Code section 11054(d)(13) and a dangerous drug according to Business and
Professions Code section 4022
FIRST CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - Assault with a Firearm)
13 Respondent is subject to disciplinary action under section 4300490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1770 in that on or about July 1 2004 Respondent was
convicted of a crime substantially related to the qualifications functions or duties of a pharmacy
technician as follows
a On or about July 1 2004 in a criminal proceeding entitled The People of
the State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court Case
No2004014916FA Respondent was convicted on a plea of guilty for violating Penal Code
section 245( a)(2) (assault with a firearm) a felony and the special allegation of Penal Code
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section 12022S(a)(I) (use ofa firearm) a felony On or about August 30 2004 Respondent was
sentenced to serve five (5) years in the Department of Corrections
b The circumstances underlying the conviction are that on or about April 10
2004 Respondent was arrested after making violent andor death threats brandishing a Glock 40
caliber pistol and during a physical altercation shooting victim Michael M in the left shoulder
with the pistol
SECOND CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - DUI)
14 Respondent is subject to disciplinary action under section 4300 490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1770 in that on or about February 5 2003 Respondent
was convicted of a crime substantially related to the qualifications functions or duties of a
pharmacy technician as follows
a On or about February 5 2003 in a criminal proceeding entitled The
People ofthe State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court
Case No 2003001701 MA Respondent was convicted on a plea of guilty for violating Vehicle
Code section 23152b) (driving while having a 008 or higher blood alcohol content) a
misdemeanor
b The circumstances underlying the conviction are that on or about
January 52003 Respondent was arrested for driving under the influence of an alcoholic
beverage Respondents blood alcohol content tested at 013
TIDRD CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - Possession of Marijuana)
15 Respondent is subject to disciplinary action under section 4300 490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1710 in that on or about February 2 2000 Respondent
was convicted of a crime substantially related to the qualifications functions or duties of a
phatmacy technician as follows
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a On or about February 2 2000 in a criminal proceeding entitled The
People ofthe State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court
Case No 00M009643MA Respondent was convicted on a plea of guilty for violating Vehicle
code section 23222(b) (possession of marijuana in vehicle) a misdemeanor
b The circumstances underlying the conviction are that on or about
January 5 2000 Respondent was in possession of the controlled substance and dangerous drug
marijuana while driving a vehicle
FOURTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Possessions of Controlled Substance I Dangerous Drug - Marijuana)
16 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision 0) on the grounds of unprofessional conduct for violating section 4060 in that on or
about January 5 2000 Respondent was in possession of marijuana a controlled substance and
dangerous drug without a valid prescription
FIFTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Dishonest Acts)
17 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision (f) on the grounds of unprofessional conduct in that Respondent committed acts
involving moral turpitude dishonesty fraud deceit or corruption as set forth above in paragraphs
13 through 16 and incorporated herein by reference
SIXTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Acts Warranting Denial of Licensure)
18 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision (p) on the grounds of unprofessional conduct in conjunction with section 475
subdivisions (a)(2) (a)(3) and (a)(4) in that Respondent committed acts which would warrant
denial of licensure as set forth above in paragraphs 13 through 17 and incorporated herein by
reference
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PRAYER
WHEREFORE Complainant requests that a hearing be held on the matters herein
alleged and that following the hearing the Board of Pharmacy issue a decision
A Revoking or suspending Pharmacy Technician Registration No TCH
44940 issued to Christian Bevan Williams
B Ordering Christian Bevan Williams to pay the Board of Pharmacy the
reasonable costs of the investigation and enforcement of this case pursuant to Business and
Professions Code section 1253
C Taking such other and further action as deemed necessary and proper
DATED 10105
PATRICIAF HARRIS Executive Officer Board of Pharmacy Department of Consumer Affairs State of California
Complainant
7
DECLARATION OF SERVICE BY CERTIFIED MAIL AND FIRST CLASS MAIL (Separate Mailings)
Case Name In the Matter of the Accusation Against Christian Bevan Williams Case No 2871
I declare
I am employed in the Office of the Attorney General which is the office of a member of the California State Bar at which members direction this service is made I am 18 years of age or older and not a party to this matter I am familiar with the business practice at the Office of the Attorney General for collection and processing of correspondence for mailing with the United States Postal Service In accordance with that practice correspondence placed in the internal mail collection system at the Office of the Attorney General is deposited with the United States Postal Service that same day in the ordinary course ofbusiness
On November 30 2005 I served the attached Accusation Statement to Respondent Request for Discovery Notice of Defense and Government Code sections by placing a true copy thereof enclosed in a sealed envelope as certified mail with postage thereon fully prepaid and return receipt requested and another true copy of the Accusation Statement to Respondent Request for Discovery Notice of Defense and Government Code sections was enclosed in a second sealed envelope as first class mail with postage thereon fully prepaid in the internal mail collection system at the Office of the Attorney General at Los Angeles addressed as follows
Christian Bevan Williams 9 Poinsettia Gardens Drive Ventura CA 93004
Certified Mail Receipt No 7001 0360 0003 2701 4893
Christian Bevan Williams
Susan Cappello Enforcement Analyst Board of Pharmacy 400 R Street Suite 4070 Sacramento CA 95814-6200
=I CJ rshyru rn CJ CJ CJ
CJ D rn CJ
=I CJ CJ rshy
=I CJ rshyru rn Cl Cl Cl
Cl D rn Cl
r-=1 Cl Cl r-
Postmark HOl8 vs of the State of California the foregoing is tnle
ted on November 30 2005 at Los Angeles
Exhibit B
Postal Return Document
o Agent
o Addressee
D Is delivery address different from item 1 0 Yes
If YES enter delivery address below 0 No
~~lv0-wt)
Ace c~G~i-SENDER COMPLETE THIS SECTION
bull Complete items 1 2 and 3 Also complete item 4 if RestrictedDelivery is desired
bull Print your name and address on the reverse so that we can return the card to you
bull Attach this card to the back of the mail piece or on the front if space permits
1 Article Addressed to
Christian Bevan Villiams co Sierra Conservation Center Inmate Reg No V50004 PO Box 497 5100 O-Byrnes Ferry Road Jamestown CA 95327
3 Service Type
Ji( Certified Mail o Registered
o Insured Mail
Express Mail
COD
4 Restricted Delivery (Extra Fee) 0 Y
i Return Receipt for Merchandise
es
2 Article Number (Copy from service label) 7001 0360 0003 2701 4886
PS Form 3811 July 1999 Domestic Return Receipt 102595-00-M-0952
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a Notice ofAutomatic Suspension of License The Pharmacy Technician Registration will expire
on April 30 2006 unless renewed
JURISDICTION
3 This Accusation is brought before the Board under the authority of the
following laws All section references are to the Business and Professions Code unless otherwise
indicated
4 Section 4300 permits the Board to take disciplinary action to suspend or
revoke a license or permit
E Section 118 subdivision (b) provides that the suspension
expirationsurrendercancellation of a license shall not deprive the Board ofjurisdiction to
proceed with a disciplinary action during the period within which the license may be renewed
restored reissued or reinstated
F Section 490 states
A board may suspend or revoke a license on the ground that the licensee has been
convicted of a crime if the crime is substantially related to the qualifications functions or duties
of the business or profession for which the license was issued A conviction within the meaning
of this section means a plea or verdict of guilty or a conviction following a plea of nolo
contendere Any action which a board is permitted to take following the establishment of a
conviction may be taken when the time for appeal has elapsed or the judgment of conviction has
been affinned on appeal or when an order granting probation is made suspending the imposition
of sentence irrespective of a subsequent order under the provisions of Section 12034 of the
Penal Code
7 Section 4301 states in pertinent part
The board shall take action against any holder of a license who is guilty of
unprofessional conduct or whose license has been procured by fraud or misrepresentation or
issued by mistake Unprofessional conduct shall include but is not limited to any of the
following
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(f) The commission of any act involving moral turpitude dishonesty fraud
deceit or corruption whether the act is committed in the course of relations as a licensee or
otherwise and whether the act is a felony or misdemeanor or not
0) The violation of any of the statutes of this state or of the United States
regulating controlled substances and dangerous drugs
n(l) The conviction of a crime substantially related to the qualifications functions
and duties of a licensee under this chapter The record of conviction shall be conclusive
evidence only of the fact that the conviction occurred
nco) Violating or attempting to violate directly or indirectly or assisting in or
abetting the violation of or conspiring to violate any provision or term of this chapter or of the
applicable federal and state laws and regulations governing pharmacy including regulations
established by the board
(p) Actions or conduct that would have warranted denial of a license
8 Section 4060 states in pertinent part that [n]o person shall possess any
controlled substance except that furnished to a person upon the prescription of a physician
dentist podiatrist or veterinarian or furnished pursuant to a drug order issued by a certified
nurse-midwife pursuant to Section 274651 a nurse practitioner pursuant to Section 28361 or a
physician assistant pursuant to Section 35021
9 California Code of Regulations title 16 section 1770 states
For the purpose of denial suspension or revocation of a personal or facility
license pursuant to Division 15 (commencing with Section 475) of the Business and Professions
Code a crime or act shall be considered substantially related to the qualifications functions or
duties of a licensee or registrant if to a substantial degree it evidences present or potential
unfitness of a licensee or registrant to perform the functions authorized by his license or
registration in a manner consistent with the public health safety or welfare
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10 Section 475 states in pertinent part
(a) Notwithstanding any other provisions of this code the provisions of this
division shall govern the denial of licenses on the grounds of
(2) Conviction of a crime
(3) Commission of any act involving dishonesty fraud or deceit with the intent
to substantially benefit himself or another or substantially injure another
(4) Commission of any act which if done by a licentiate of the business or
profession inquestion would be grounds for suspension or revocation of license
11 Section 1253 states in pertinent part that the Board may request the
administrative law judge to direct a licentiate found to have committed a violation or violations
of the licensing act to pay a sum not to exceed the reasonable costs of the investigation and
enforcement of the case
CONTROLLED SUBSTANCES I DANGEROUS DRUGS
12 Marijuana is a hallucinogenic Schedule I controlled substance as defined
in Health and Safety Code section 11054(d)(13) and a dangerous drug according to Business and
Professions Code section 4022
FIRST CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - Assault with a Firearm)
13 Respondent is subject to disciplinary action under section 4300490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1770 in that on or about July 1 2004 Respondent was
convicted of a crime substantially related to the qualifications functions or duties of a pharmacy
technician as follows
a On or about July 1 2004 in a criminal proceeding entitled The People of
the State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court Case
No2004014916FA Respondent was convicted on a plea of guilty for violating Penal Code
section 245( a)(2) (assault with a firearm) a felony and the special allegation of Penal Code
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section 12022S(a)(I) (use ofa firearm) a felony On or about August 30 2004 Respondent was
sentenced to serve five (5) years in the Department of Corrections
b The circumstances underlying the conviction are that on or about April 10
2004 Respondent was arrested after making violent andor death threats brandishing a Glock 40
caliber pistol and during a physical altercation shooting victim Michael M in the left shoulder
with the pistol
SECOND CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - DUI)
14 Respondent is subject to disciplinary action under section 4300 490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1770 in that on or about February 5 2003 Respondent
was convicted of a crime substantially related to the qualifications functions or duties of a
pharmacy technician as follows
a On or about February 5 2003 in a criminal proceeding entitled The
People ofthe State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court
Case No 2003001701 MA Respondent was convicted on a plea of guilty for violating Vehicle
Code section 23152b) (driving while having a 008 or higher blood alcohol content) a
misdemeanor
b The circumstances underlying the conviction are that on or about
January 52003 Respondent was arrested for driving under the influence of an alcoholic
beverage Respondents blood alcohol content tested at 013
TIDRD CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - Possession of Marijuana)
15 Respondent is subject to disciplinary action under section 4300 490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1710 in that on or about February 2 2000 Respondent
was convicted of a crime substantially related to the qualifications functions or duties of a
phatmacy technician as follows
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a On or about February 2 2000 in a criminal proceeding entitled The
People ofthe State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court
Case No 00M009643MA Respondent was convicted on a plea of guilty for violating Vehicle
code section 23222(b) (possession of marijuana in vehicle) a misdemeanor
b The circumstances underlying the conviction are that on or about
January 5 2000 Respondent was in possession of the controlled substance and dangerous drug
marijuana while driving a vehicle
FOURTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Possessions of Controlled Substance I Dangerous Drug - Marijuana)
16 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision 0) on the grounds of unprofessional conduct for violating section 4060 in that on or
about January 5 2000 Respondent was in possession of marijuana a controlled substance and
dangerous drug without a valid prescription
FIFTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Dishonest Acts)
17 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision (f) on the grounds of unprofessional conduct in that Respondent committed acts
involving moral turpitude dishonesty fraud deceit or corruption as set forth above in paragraphs
13 through 16 and incorporated herein by reference
SIXTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Acts Warranting Denial of Licensure)
18 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision (p) on the grounds of unprofessional conduct in conjunction with section 475
subdivisions (a)(2) (a)(3) and (a)(4) in that Respondent committed acts which would warrant
denial of licensure as set forth above in paragraphs 13 through 17 and incorporated herein by
reference
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PRAYER
WHEREFORE Complainant requests that a hearing be held on the matters herein
alleged and that following the hearing the Board of Pharmacy issue a decision
A Revoking or suspending Pharmacy Technician Registration No TCH
44940 issued to Christian Bevan Williams
B Ordering Christian Bevan Williams to pay the Board of Pharmacy the
reasonable costs of the investigation and enforcement of this case pursuant to Business and
Professions Code section 1253
C Taking such other and further action as deemed necessary and proper
DATED 10105
PATRICIAF HARRIS Executive Officer Board of Pharmacy Department of Consumer Affairs State of California
Complainant
7
DECLARATION OF SERVICE BY CERTIFIED MAIL AND FIRST CLASS MAIL (Separate Mailings)
Case Name In the Matter of the Accusation Against Christian Bevan Williams Case No 2871
I declare
I am employed in the Office of the Attorney General which is the office of a member of the California State Bar at which members direction this service is made I am 18 years of age or older and not a party to this matter I am familiar with the business practice at the Office of the Attorney General for collection and processing of correspondence for mailing with the United States Postal Service In accordance with that practice correspondence placed in the internal mail collection system at the Office of the Attorney General is deposited with the United States Postal Service that same day in the ordinary course ofbusiness
On November 30 2005 I served the attached Accusation Statement to Respondent Request for Discovery Notice of Defense and Government Code sections by placing a true copy thereof enclosed in a sealed envelope as certified mail with postage thereon fully prepaid and return receipt requested and another true copy of the Accusation Statement to Respondent Request for Discovery Notice of Defense and Government Code sections was enclosed in a second sealed envelope as first class mail with postage thereon fully prepaid in the internal mail collection system at the Office of the Attorney General at Los Angeles addressed as follows
Christian Bevan Williams 9 Poinsettia Gardens Drive Ventura CA 93004
Certified Mail Receipt No 7001 0360 0003 2701 4893
Christian Bevan Williams
Susan Cappello Enforcement Analyst Board of Pharmacy 400 R Street Suite 4070 Sacramento CA 95814-6200
=I CJ rshyru rn CJ CJ CJ
CJ D rn CJ
=I CJ CJ rshy
=I CJ rshyru rn Cl Cl Cl
Cl D rn Cl
r-=1 Cl Cl r-
Postmark HOl8 vs of the State of California the foregoing is tnle
ted on November 30 2005 at Los Angeles
Exhibit B
Postal Return Document
o Agent
o Addressee
D Is delivery address different from item 1 0 Yes
If YES enter delivery address below 0 No
~~lv0-wt)
Ace c~G~i-SENDER COMPLETE THIS SECTION
bull Complete items 1 2 and 3 Also complete item 4 if RestrictedDelivery is desired
bull Print your name and address on the reverse so that we can return the card to you
bull Attach this card to the back of the mail piece or on the front if space permits
1 Article Addressed to
Christian Bevan Villiams co Sierra Conservation Center Inmate Reg No V50004 PO Box 497 5100 O-Byrnes Ferry Road Jamestown CA 95327
3 Service Type
Ji( Certified Mail o Registered
o Insured Mail
Express Mail
COD
4 Restricted Delivery (Extra Fee) 0 Y
i Return Receipt for Merchandise
es
2 Article Number (Copy from service label) 7001 0360 0003 2701 4886
PS Form 3811 July 1999 Domestic Return Receipt 102595-00-M-0952
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(f) The commission of any act involving moral turpitude dishonesty fraud
deceit or corruption whether the act is committed in the course of relations as a licensee or
otherwise and whether the act is a felony or misdemeanor or not
0) The violation of any of the statutes of this state or of the United States
regulating controlled substances and dangerous drugs
n(l) The conviction of a crime substantially related to the qualifications functions
and duties of a licensee under this chapter The record of conviction shall be conclusive
evidence only of the fact that the conviction occurred
nco) Violating or attempting to violate directly or indirectly or assisting in or
abetting the violation of or conspiring to violate any provision or term of this chapter or of the
applicable federal and state laws and regulations governing pharmacy including regulations
established by the board
(p) Actions or conduct that would have warranted denial of a license
8 Section 4060 states in pertinent part that [n]o person shall possess any
controlled substance except that furnished to a person upon the prescription of a physician
dentist podiatrist or veterinarian or furnished pursuant to a drug order issued by a certified
nurse-midwife pursuant to Section 274651 a nurse practitioner pursuant to Section 28361 or a
physician assistant pursuant to Section 35021
9 California Code of Regulations title 16 section 1770 states
For the purpose of denial suspension or revocation of a personal or facility
license pursuant to Division 15 (commencing with Section 475) of the Business and Professions
Code a crime or act shall be considered substantially related to the qualifications functions or
duties of a licensee or registrant if to a substantial degree it evidences present or potential
unfitness of a licensee or registrant to perform the functions authorized by his license or
registration in a manner consistent with the public health safety or welfare
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10 Section 475 states in pertinent part
(a) Notwithstanding any other provisions of this code the provisions of this
division shall govern the denial of licenses on the grounds of
(2) Conviction of a crime
(3) Commission of any act involving dishonesty fraud or deceit with the intent
to substantially benefit himself or another or substantially injure another
(4) Commission of any act which if done by a licentiate of the business or
profession inquestion would be grounds for suspension or revocation of license
11 Section 1253 states in pertinent part that the Board may request the
administrative law judge to direct a licentiate found to have committed a violation or violations
of the licensing act to pay a sum not to exceed the reasonable costs of the investigation and
enforcement of the case
CONTROLLED SUBSTANCES I DANGEROUS DRUGS
12 Marijuana is a hallucinogenic Schedule I controlled substance as defined
in Health and Safety Code section 11054(d)(13) and a dangerous drug according to Business and
Professions Code section 4022
FIRST CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - Assault with a Firearm)
13 Respondent is subject to disciplinary action under section 4300490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1770 in that on or about July 1 2004 Respondent was
convicted of a crime substantially related to the qualifications functions or duties of a pharmacy
technician as follows
a On or about July 1 2004 in a criminal proceeding entitled The People of
the State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court Case
No2004014916FA Respondent was convicted on a plea of guilty for violating Penal Code
section 245( a)(2) (assault with a firearm) a felony and the special allegation of Penal Code
4
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4
5
6
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section 12022S(a)(I) (use ofa firearm) a felony On or about August 30 2004 Respondent was
sentenced to serve five (5) years in the Department of Corrections
b The circumstances underlying the conviction are that on or about April 10
2004 Respondent was arrested after making violent andor death threats brandishing a Glock 40
caliber pistol and during a physical altercation shooting victim Michael M in the left shoulder
with the pistol
SECOND CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - DUI)
14 Respondent is subject to disciplinary action under section 4300 490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1770 in that on or about February 5 2003 Respondent
was convicted of a crime substantially related to the qualifications functions or duties of a
pharmacy technician as follows
a On or about February 5 2003 in a criminal proceeding entitled The
People ofthe State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court
Case No 2003001701 MA Respondent was convicted on a plea of guilty for violating Vehicle
Code section 23152b) (driving while having a 008 or higher blood alcohol content) a
misdemeanor
b The circumstances underlying the conviction are that on or about
January 52003 Respondent was arrested for driving under the influence of an alcoholic
beverage Respondents blood alcohol content tested at 013
TIDRD CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - Possession of Marijuana)
15 Respondent is subject to disciplinary action under section 4300 490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1710 in that on or about February 2 2000 Respondent
was convicted of a crime substantially related to the qualifications functions or duties of a
phatmacy technician as follows
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a On or about February 2 2000 in a criminal proceeding entitled The
People ofthe State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court
Case No 00M009643MA Respondent was convicted on a plea of guilty for violating Vehicle
code section 23222(b) (possession of marijuana in vehicle) a misdemeanor
b The circumstances underlying the conviction are that on or about
January 5 2000 Respondent was in possession of the controlled substance and dangerous drug
marijuana while driving a vehicle
FOURTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Possessions of Controlled Substance I Dangerous Drug - Marijuana)
16 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision 0) on the grounds of unprofessional conduct for violating section 4060 in that on or
about January 5 2000 Respondent was in possession of marijuana a controlled substance and
dangerous drug without a valid prescription
FIFTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Dishonest Acts)
17 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision (f) on the grounds of unprofessional conduct in that Respondent committed acts
involving moral turpitude dishonesty fraud deceit or corruption as set forth above in paragraphs
13 through 16 and incorporated herein by reference
SIXTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Acts Warranting Denial of Licensure)
18 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision (p) on the grounds of unprofessional conduct in conjunction with section 475
subdivisions (a)(2) (a)(3) and (a)(4) in that Respondent committed acts which would warrant
denial of licensure as set forth above in paragraphs 13 through 17 and incorporated herein by
reference
I I I
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fJ~
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PRAYER
WHEREFORE Complainant requests that a hearing be held on the matters herein
alleged and that following the hearing the Board of Pharmacy issue a decision
A Revoking or suspending Pharmacy Technician Registration No TCH
44940 issued to Christian Bevan Williams
B Ordering Christian Bevan Williams to pay the Board of Pharmacy the
reasonable costs of the investigation and enforcement of this case pursuant to Business and
Professions Code section 1253
C Taking such other and further action as deemed necessary and proper
DATED 10105
PATRICIAF HARRIS Executive Officer Board of Pharmacy Department of Consumer Affairs State of California
Complainant
7
DECLARATION OF SERVICE BY CERTIFIED MAIL AND FIRST CLASS MAIL (Separate Mailings)
Case Name In the Matter of the Accusation Against Christian Bevan Williams Case No 2871
I declare
I am employed in the Office of the Attorney General which is the office of a member of the California State Bar at which members direction this service is made I am 18 years of age or older and not a party to this matter I am familiar with the business practice at the Office of the Attorney General for collection and processing of correspondence for mailing with the United States Postal Service In accordance with that practice correspondence placed in the internal mail collection system at the Office of the Attorney General is deposited with the United States Postal Service that same day in the ordinary course ofbusiness
On November 30 2005 I served the attached Accusation Statement to Respondent Request for Discovery Notice of Defense and Government Code sections by placing a true copy thereof enclosed in a sealed envelope as certified mail with postage thereon fully prepaid and return receipt requested and another true copy of the Accusation Statement to Respondent Request for Discovery Notice of Defense and Government Code sections was enclosed in a second sealed envelope as first class mail with postage thereon fully prepaid in the internal mail collection system at the Office of the Attorney General at Los Angeles addressed as follows
Christian Bevan Williams 9 Poinsettia Gardens Drive Ventura CA 93004
Certified Mail Receipt No 7001 0360 0003 2701 4893
Christian Bevan Williams
Susan Cappello Enforcement Analyst Board of Pharmacy 400 R Street Suite 4070 Sacramento CA 95814-6200
=I CJ rshyru rn CJ CJ CJ
CJ D rn CJ
=I CJ CJ rshy
=I CJ rshyru rn Cl Cl Cl
Cl D rn Cl
r-=1 Cl Cl r-
Postmark HOl8 vs of the State of California the foregoing is tnle
ted on November 30 2005 at Los Angeles
Exhibit B
Postal Return Document
o Agent
o Addressee
D Is delivery address different from item 1 0 Yes
If YES enter delivery address below 0 No
~~lv0-wt)
Ace c~G~i-SENDER COMPLETE THIS SECTION
bull Complete items 1 2 and 3 Also complete item 4 if RestrictedDelivery is desired
bull Print your name and address on the reverse so that we can return the card to you
bull Attach this card to the back of the mail piece or on the front if space permits
1 Article Addressed to
Christian Bevan Villiams co Sierra Conservation Center Inmate Reg No V50004 PO Box 497 5100 O-Byrnes Ferry Road Jamestown CA 95327
3 Service Type
Ji( Certified Mail o Registered
o Insured Mail
Express Mail
COD
4 Restricted Delivery (Extra Fee) 0 Y
i Return Receipt for Merchandise
es
2 Article Number (Copy from service label) 7001 0360 0003 2701 4886
PS Form 3811 July 1999 Domestic Return Receipt 102595-00-M-0952
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10 Section 475 states in pertinent part
(a) Notwithstanding any other provisions of this code the provisions of this
division shall govern the denial of licenses on the grounds of
(2) Conviction of a crime
(3) Commission of any act involving dishonesty fraud or deceit with the intent
to substantially benefit himself or another or substantially injure another
(4) Commission of any act which if done by a licentiate of the business or
profession inquestion would be grounds for suspension or revocation of license
11 Section 1253 states in pertinent part that the Board may request the
administrative law judge to direct a licentiate found to have committed a violation or violations
of the licensing act to pay a sum not to exceed the reasonable costs of the investigation and
enforcement of the case
CONTROLLED SUBSTANCES I DANGEROUS DRUGS
12 Marijuana is a hallucinogenic Schedule I controlled substance as defined
in Health and Safety Code section 11054(d)(13) and a dangerous drug according to Business and
Professions Code section 4022
FIRST CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - Assault with a Firearm)
13 Respondent is subject to disciplinary action under section 4300490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1770 in that on or about July 1 2004 Respondent was
convicted of a crime substantially related to the qualifications functions or duties of a pharmacy
technician as follows
a On or about July 1 2004 in a criminal proceeding entitled The People of
the State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court Case
No2004014916FA Respondent was convicted on a plea of guilty for violating Penal Code
section 245( a)(2) (assault with a firearm) a felony and the special allegation of Penal Code
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section 12022S(a)(I) (use ofa firearm) a felony On or about August 30 2004 Respondent was
sentenced to serve five (5) years in the Department of Corrections
b The circumstances underlying the conviction are that on or about April 10
2004 Respondent was arrested after making violent andor death threats brandishing a Glock 40
caliber pistol and during a physical altercation shooting victim Michael M in the left shoulder
with the pistol
SECOND CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - DUI)
14 Respondent is subject to disciplinary action under section 4300 490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1770 in that on or about February 5 2003 Respondent
was convicted of a crime substantially related to the qualifications functions or duties of a
pharmacy technician as follows
a On or about February 5 2003 in a criminal proceeding entitled The
People ofthe State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court
Case No 2003001701 MA Respondent was convicted on a plea of guilty for violating Vehicle
Code section 23152b) (driving while having a 008 or higher blood alcohol content) a
misdemeanor
b The circumstances underlying the conviction are that on or about
January 52003 Respondent was arrested for driving under the influence of an alcoholic
beverage Respondents blood alcohol content tested at 013
TIDRD CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - Possession of Marijuana)
15 Respondent is subject to disciplinary action under section 4300 490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1710 in that on or about February 2 2000 Respondent
was convicted of a crime substantially related to the qualifications functions or duties of a
phatmacy technician as follows
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a On or about February 2 2000 in a criminal proceeding entitled The
People ofthe State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court
Case No 00M009643MA Respondent was convicted on a plea of guilty for violating Vehicle
code section 23222(b) (possession of marijuana in vehicle) a misdemeanor
b The circumstances underlying the conviction are that on or about
January 5 2000 Respondent was in possession of the controlled substance and dangerous drug
marijuana while driving a vehicle
FOURTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Possessions of Controlled Substance I Dangerous Drug - Marijuana)
16 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision 0) on the grounds of unprofessional conduct for violating section 4060 in that on or
about January 5 2000 Respondent was in possession of marijuana a controlled substance and
dangerous drug without a valid prescription
FIFTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Dishonest Acts)
17 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision (f) on the grounds of unprofessional conduct in that Respondent committed acts
involving moral turpitude dishonesty fraud deceit or corruption as set forth above in paragraphs
13 through 16 and incorporated herein by reference
SIXTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Acts Warranting Denial of Licensure)
18 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision (p) on the grounds of unprofessional conduct in conjunction with section 475
subdivisions (a)(2) (a)(3) and (a)(4) in that Respondent committed acts which would warrant
denial of licensure as set forth above in paragraphs 13 through 17 and incorporated herein by
reference
I I I
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PRAYER
WHEREFORE Complainant requests that a hearing be held on the matters herein
alleged and that following the hearing the Board of Pharmacy issue a decision
A Revoking or suspending Pharmacy Technician Registration No TCH
44940 issued to Christian Bevan Williams
B Ordering Christian Bevan Williams to pay the Board of Pharmacy the
reasonable costs of the investigation and enforcement of this case pursuant to Business and
Professions Code section 1253
C Taking such other and further action as deemed necessary and proper
DATED 10105
PATRICIAF HARRIS Executive Officer Board of Pharmacy Department of Consumer Affairs State of California
Complainant
7
DECLARATION OF SERVICE BY CERTIFIED MAIL AND FIRST CLASS MAIL (Separate Mailings)
Case Name In the Matter of the Accusation Against Christian Bevan Williams Case No 2871
I declare
I am employed in the Office of the Attorney General which is the office of a member of the California State Bar at which members direction this service is made I am 18 years of age or older and not a party to this matter I am familiar with the business practice at the Office of the Attorney General for collection and processing of correspondence for mailing with the United States Postal Service In accordance with that practice correspondence placed in the internal mail collection system at the Office of the Attorney General is deposited with the United States Postal Service that same day in the ordinary course ofbusiness
On November 30 2005 I served the attached Accusation Statement to Respondent Request for Discovery Notice of Defense and Government Code sections by placing a true copy thereof enclosed in a sealed envelope as certified mail with postage thereon fully prepaid and return receipt requested and another true copy of the Accusation Statement to Respondent Request for Discovery Notice of Defense and Government Code sections was enclosed in a second sealed envelope as first class mail with postage thereon fully prepaid in the internal mail collection system at the Office of the Attorney General at Los Angeles addressed as follows
Christian Bevan Williams 9 Poinsettia Gardens Drive Ventura CA 93004
Certified Mail Receipt No 7001 0360 0003 2701 4893
Christian Bevan Williams
Susan Cappello Enforcement Analyst Board of Pharmacy 400 R Street Suite 4070 Sacramento CA 95814-6200
=I CJ rshyru rn CJ CJ CJ
CJ D rn CJ
=I CJ CJ rshy
=I CJ rshyru rn Cl Cl Cl
Cl D rn Cl
r-=1 Cl Cl r-
Postmark HOl8 vs of the State of California the foregoing is tnle
ted on November 30 2005 at Los Angeles
Exhibit B
Postal Return Document
o Agent
o Addressee
D Is delivery address different from item 1 0 Yes
If YES enter delivery address below 0 No
~~lv0-wt)
Ace c~G~i-SENDER COMPLETE THIS SECTION
bull Complete items 1 2 and 3 Also complete item 4 if RestrictedDelivery is desired
bull Print your name and address on the reverse so that we can return the card to you
bull Attach this card to the back of the mail piece or on the front if space permits
1 Article Addressed to
Christian Bevan Villiams co Sierra Conservation Center Inmate Reg No V50004 PO Box 497 5100 O-Byrnes Ferry Road Jamestown CA 95327
3 Service Type
Ji( Certified Mail o Registered
o Insured Mail
Express Mail
COD
4 Restricted Delivery (Extra Fee) 0 Y
i Return Receipt for Merchandise
es
2 Article Number (Copy from service label) 7001 0360 0003 2701 4886
PS Form 3811 July 1999 Domestic Return Receipt 102595-00-M-0952
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section 12022S(a)(I) (use ofa firearm) a felony On or about August 30 2004 Respondent was
sentenced to serve five (5) years in the Department of Corrections
b The circumstances underlying the conviction are that on or about April 10
2004 Respondent was arrested after making violent andor death threats brandishing a Glock 40
caliber pistol and during a physical altercation shooting victim Michael M in the left shoulder
with the pistol
SECOND CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - DUI)
14 Respondent is subject to disciplinary action under section 4300 490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1770 in that on or about February 5 2003 Respondent
was convicted of a crime substantially related to the qualifications functions or duties of a
pharmacy technician as follows
a On or about February 5 2003 in a criminal proceeding entitled The
People ofthe State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court
Case No 2003001701 MA Respondent was convicted on a plea of guilty for violating Vehicle
Code section 23152b) (driving while having a 008 or higher blood alcohol content) a
misdemeanor
b The circumstances underlying the conviction are that on or about
January 52003 Respondent was arrested for driving under the influence of an alcoholic
beverage Respondents blood alcohol content tested at 013
TIDRD CAUSE FOR DISCIPLINE
(Unprofessional Conduct Conviction of Substantially Related Crime - Possession of Marijuana)
15 Respondent is subject to disciplinary action under section 4300 490 and
4301 subdivision (1) on the grounds of unprofessional conduct in conjunction with California
Code of Regulations title 16 section 1710 in that on or about February 2 2000 Respondent
was convicted of a crime substantially related to the qualifications functions or duties of a
phatmacy technician as follows
5
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a On or about February 2 2000 in a criminal proceeding entitled The
People ofthe State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court
Case No 00M009643MA Respondent was convicted on a plea of guilty for violating Vehicle
code section 23222(b) (possession of marijuana in vehicle) a misdemeanor
b The circumstances underlying the conviction are that on or about
January 5 2000 Respondent was in possession of the controlled substance and dangerous drug
marijuana while driving a vehicle
FOURTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Possessions of Controlled Substance I Dangerous Drug - Marijuana)
16 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision 0) on the grounds of unprofessional conduct for violating section 4060 in that on or
about January 5 2000 Respondent was in possession of marijuana a controlled substance and
dangerous drug without a valid prescription
FIFTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Dishonest Acts)
17 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision (f) on the grounds of unprofessional conduct in that Respondent committed acts
involving moral turpitude dishonesty fraud deceit or corruption as set forth above in paragraphs
13 through 16 and incorporated herein by reference
SIXTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Acts Warranting Denial of Licensure)
18 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision (p) on the grounds of unprofessional conduct in conjunction with section 475
subdivisions (a)(2) (a)(3) and (a)(4) in that Respondent committed acts which would warrant
denial of licensure as set forth above in paragraphs 13 through 17 and incorporated herein by
reference
I I I
6
III
fJ~
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PRAYER
WHEREFORE Complainant requests that a hearing be held on the matters herein
alleged and that following the hearing the Board of Pharmacy issue a decision
A Revoking or suspending Pharmacy Technician Registration No TCH
44940 issued to Christian Bevan Williams
B Ordering Christian Bevan Williams to pay the Board of Pharmacy the
reasonable costs of the investigation and enforcement of this case pursuant to Business and
Professions Code section 1253
C Taking such other and further action as deemed necessary and proper
DATED 10105
PATRICIAF HARRIS Executive Officer Board of Pharmacy Department of Consumer Affairs State of California
Complainant
7
DECLARATION OF SERVICE BY CERTIFIED MAIL AND FIRST CLASS MAIL (Separate Mailings)
Case Name In the Matter of the Accusation Against Christian Bevan Williams Case No 2871
I declare
I am employed in the Office of the Attorney General which is the office of a member of the California State Bar at which members direction this service is made I am 18 years of age or older and not a party to this matter I am familiar with the business practice at the Office of the Attorney General for collection and processing of correspondence for mailing with the United States Postal Service In accordance with that practice correspondence placed in the internal mail collection system at the Office of the Attorney General is deposited with the United States Postal Service that same day in the ordinary course ofbusiness
On November 30 2005 I served the attached Accusation Statement to Respondent Request for Discovery Notice of Defense and Government Code sections by placing a true copy thereof enclosed in a sealed envelope as certified mail with postage thereon fully prepaid and return receipt requested and another true copy of the Accusation Statement to Respondent Request for Discovery Notice of Defense and Government Code sections was enclosed in a second sealed envelope as first class mail with postage thereon fully prepaid in the internal mail collection system at the Office of the Attorney General at Los Angeles addressed as follows
Christian Bevan Williams 9 Poinsettia Gardens Drive Ventura CA 93004
Certified Mail Receipt No 7001 0360 0003 2701 4893
Christian Bevan Williams
Susan Cappello Enforcement Analyst Board of Pharmacy 400 R Street Suite 4070 Sacramento CA 95814-6200
=I CJ rshyru rn CJ CJ CJ
CJ D rn CJ
=I CJ CJ rshy
=I CJ rshyru rn Cl Cl Cl
Cl D rn Cl
r-=1 Cl Cl r-
Postmark HOl8 vs of the State of California the foregoing is tnle
ted on November 30 2005 at Los Angeles
Exhibit B
Postal Return Document
o Agent
o Addressee
D Is delivery address different from item 1 0 Yes
If YES enter delivery address below 0 No
~~lv0-wt)
Ace c~G~i-SENDER COMPLETE THIS SECTION
bull Complete items 1 2 and 3 Also complete item 4 if RestrictedDelivery is desired
bull Print your name and address on the reverse so that we can return the card to you
bull Attach this card to the back of the mail piece or on the front if space permits
1 Article Addressed to
Christian Bevan Villiams co Sierra Conservation Center Inmate Reg No V50004 PO Box 497 5100 O-Byrnes Ferry Road Jamestown CA 95327
3 Service Type
Ji( Certified Mail o Registered
o Insured Mail
Express Mail
COD
4 Restricted Delivery (Extra Fee) 0 Y
i Return Receipt for Merchandise
es
2 Article Number (Copy from service label) 7001 0360 0003 2701 4886
PS Form 3811 July 1999 Domestic Return Receipt 102595-00-M-0952
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a On or about February 2 2000 in a criminal proceeding entitled The
People ofthe State ofCalifornia v Christian Bevan Williams in Ventura County Superior Court
Case No 00M009643MA Respondent was convicted on a plea of guilty for violating Vehicle
code section 23222(b) (possession of marijuana in vehicle) a misdemeanor
b The circumstances underlying the conviction are that on or about
January 5 2000 Respondent was in possession of the controlled substance and dangerous drug
marijuana while driving a vehicle
FOURTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Possessions of Controlled Substance I Dangerous Drug - Marijuana)
16 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision 0) on the grounds of unprofessional conduct for violating section 4060 in that on or
about January 5 2000 Respondent was in possession of marijuana a controlled substance and
dangerous drug without a valid prescription
FIFTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Dishonest Acts)
17 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision (f) on the grounds of unprofessional conduct in that Respondent committed acts
involving moral turpitude dishonesty fraud deceit or corruption as set forth above in paragraphs
13 through 16 and incorporated herein by reference
SIXTH CAUSE FOR DISCIPLINE
(Unprofessional Conduct Acts Warranting Denial of Licensure)
18 Respondent is subject to disciplinary action under section 4300 and 4301
subdivision (p) on the grounds of unprofessional conduct in conjunction with section 475
subdivisions (a)(2) (a)(3) and (a)(4) in that Respondent committed acts which would warrant
denial of licensure as set forth above in paragraphs 13 through 17 and incorporated herein by
reference
I I I
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PRAYER
WHEREFORE Complainant requests that a hearing be held on the matters herein
alleged and that following the hearing the Board of Pharmacy issue a decision
A Revoking or suspending Pharmacy Technician Registration No TCH
44940 issued to Christian Bevan Williams
B Ordering Christian Bevan Williams to pay the Board of Pharmacy the
reasonable costs of the investigation and enforcement of this case pursuant to Business and
Professions Code section 1253
C Taking such other and further action as deemed necessary and proper
DATED 10105
PATRICIAF HARRIS Executive Officer Board of Pharmacy Department of Consumer Affairs State of California
Complainant
7
DECLARATION OF SERVICE BY CERTIFIED MAIL AND FIRST CLASS MAIL (Separate Mailings)
Case Name In the Matter of the Accusation Against Christian Bevan Williams Case No 2871
I declare
I am employed in the Office of the Attorney General which is the office of a member of the California State Bar at which members direction this service is made I am 18 years of age or older and not a party to this matter I am familiar with the business practice at the Office of the Attorney General for collection and processing of correspondence for mailing with the United States Postal Service In accordance with that practice correspondence placed in the internal mail collection system at the Office of the Attorney General is deposited with the United States Postal Service that same day in the ordinary course ofbusiness
On November 30 2005 I served the attached Accusation Statement to Respondent Request for Discovery Notice of Defense and Government Code sections by placing a true copy thereof enclosed in a sealed envelope as certified mail with postage thereon fully prepaid and return receipt requested and another true copy of the Accusation Statement to Respondent Request for Discovery Notice of Defense and Government Code sections was enclosed in a second sealed envelope as first class mail with postage thereon fully prepaid in the internal mail collection system at the Office of the Attorney General at Los Angeles addressed as follows
Christian Bevan Williams 9 Poinsettia Gardens Drive Ventura CA 93004
Certified Mail Receipt No 7001 0360 0003 2701 4893
Christian Bevan Williams
Susan Cappello Enforcement Analyst Board of Pharmacy 400 R Street Suite 4070 Sacramento CA 95814-6200
=I CJ rshyru rn CJ CJ CJ
CJ D rn CJ
=I CJ CJ rshy
=I CJ rshyru rn Cl Cl Cl
Cl D rn Cl
r-=1 Cl Cl r-
Postmark HOl8 vs of the State of California the foregoing is tnle
ted on November 30 2005 at Los Angeles
Exhibit B
Postal Return Document
o Agent
o Addressee
D Is delivery address different from item 1 0 Yes
If YES enter delivery address below 0 No
~~lv0-wt)
Ace c~G~i-SENDER COMPLETE THIS SECTION
bull Complete items 1 2 and 3 Also complete item 4 if RestrictedDelivery is desired
bull Print your name and address on the reverse so that we can return the card to you
bull Attach this card to the back of the mail piece or on the front if space permits
1 Article Addressed to
Christian Bevan Villiams co Sierra Conservation Center Inmate Reg No V50004 PO Box 497 5100 O-Byrnes Ferry Road Jamestown CA 95327
3 Service Type
Ji( Certified Mail o Registered
o Insured Mail
Express Mail
COD
4 Restricted Delivery (Extra Fee) 0 Y
i Return Receipt for Merchandise
es
2 Article Number (Copy from service label) 7001 0360 0003 2701 4886
PS Form 3811 July 1999 Domestic Return Receipt 102595-00-M-0952
fJ~
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PRAYER
WHEREFORE Complainant requests that a hearing be held on the matters herein
alleged and that following the hearing the Board of Pharmacy issue a decision
A Revoking or suspending Pharmacy Technician Registration No TCH
44940 issued to Christian Bevan Williams
B Ordering Christian Bevan Williams to pay the Board of Pharmacy the
reasonable costs of the investigation and enforcement of this case pursuant to Business and
Professions Code section 1253
C Taking such other and further action as deemed necessary and proper
DATED 10105
PATRICIAF HARRIS Executive Officer Board of Pharmacy Department of Consumer Affairs State of California
Complainant
7
DECLARATION OF SERVICE BY CERTIFIED MAIL AND FIRST CLASS MAIL (Separate Mailings)
Case Name In the Matter of the Accusation Against Christian Bevan Williams Case No 2871
I declare
I am employed in the Office of the Attorney General which is the office of a member of the California State Bar at which members direction this service is made I am 18 years of age or older and not a party to this matter I am familiar with the business practice at the Office of the Attorney General for collection and processing of correspondence for mailing with the United States Postal Service In accordance with that practice correspondence placed in the internal mail collection system at the Office of the Attorney General is deposited with the United States Postal Service that same day in the ordinary course ofbusiness
On November 30 2005 I served the attached Accusation Statement to Respondent Request for Discovery Notice of Defense and Government Code sections by placing a true copy thereof enclosed in a sealed envelope as certified mail with postage thereon fully prepaid and return receipt requested and another true copy of the Accusation Statement to Respondent Request for Discovery Notice of Defense and Government Code sections was enclosed in a second sealed envelope as first class mail with postage thereon fully prepaid in the internal mail collection system at the Office of the Attorney General at Los Angeles addressed as follows
Christian Bevan Williams 9 Poinsettia Gardens Drive Ventura CA 93004
Certified Mail Receipt No 7001 0360 0003 2701 4893
Christian Bevan Williams
Susan Cappello Enforcement Analyst Board of Pharmacy 400 R Street Suite 4070 Sacramento CA 95814-6200
=I CJ rshyru rn CJ CJ CJ
CJ D rn CJ
=I CJ CJ rshy
=I CJ rshyru rn Cl Cl Cl
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Postmark HOl8 vs of the State of California the foregoing is tnle
ted on November 30 2005 at Los Angeles
Exhibit B
Postal Return Document
o Agent
o Addressee
D Is delivery address different from item 1 0 Yes
If YES enter delivery address below 0 No
~~lv0-wt)
Ace c~G~i-SENDER COMPLETE THIS SECTION
bull Complete items 1 2 and 3 Also complete item 4 if RestrictedDelivery is desired
bull Print your name and address on the reverse so that we can return the card to you
bull Attach this card to the back of the mail piece or on the front if space permits
1 Article Addressed to
Christian Bevan Villiams co Sierra Conservation Center Inmate Reg No V50004 PO Box 497 5100 O-Byrnes Ferry Road Jamestown CA 95327
3 Service Type
Ji( Certified Mail o Registered
o Insured Mail
Express Mail
COD
4 Restricted Delivery (Extra Fee) 0 Y
i Return Receipt for Merchandise
es
2 Article Number (Copy from service label) 7001 0360 0003 2701 4886
PS Form 3811 July 1999 Domestic Return Receipt 102595-00-M-0952
DECLARATION OF SERVICE BY CERTIFIED MAIL AND FIRST CLASS MAIL (Separate Mailings)
Case Name In the Matter of the Accusation Against Christian Bevan Williams Case No 2871
I declare
I am employed in the Office of the Attorney General which is the office of a member of the California State Bar at which members direction this service is made I am 18 years of age or older and not a party to this matter I am familiar with the business practice at the Office of the Attorney General for collection and processing of correspondence for mailing with the United States Postal Service In accordance with that practice correspondence placed in the internal mail collection system at the Office of the Attorney General is deposited with the United States Postal Service that same day in the ordinary course ofbusiness
On November 30 2005 I served the attached Accusation Statement to Respondent Request for Discovery Notice of Defense and Government Code sections by placing a true copy thereof enclosed in a sealed envelope as certified mail with postage thereon fully prepaid and return receipt requested and another true copy of the Accusation Statement to Respondent Request for Discovery Notice of Defense and Government Code sections was enclosed in a second sealed envelope as first class mail with postage thereon fully prepaid in the internal mail collection system at the Office of the Attorney General at Los Angeles addressed as follows
Christian Bevan Williams 9 Poinsettia Gardens Drive Ventura CA 93004
Certified Mail Receipt No 7001 0360 0003 2701 4893
Christian Bevan Williams
Susan Cappello Enforcement Analyst Board of Pharmacy 400 R Street Suite 4070 Sacramento CA 95814-6200
=I CJ rshyru rn CJ CJ CJ
CJ D rn CJ
=I CJ CJ rshy
=I CJ rshyru rn Cl Cl Cl
Cl D rn Cl
r-=1 Cl Cl r-
Postmark HOl8 vs of the State of California the foregoing is tnle
ted on November 30 2005 at Los Angeles
Exhibit B
Postal Return Document
o Agent
o Addressee
D Is delivery address different from item 1 0 Yes
If YES enter delivery address below 0 No
~~lv0-wt)
Ace c~G~i-SENDER COMPLETE THIS SECTION
bull Complete items 1 2 and 3 Also complete item 4 if RestrictedDelivery is desired
bull Print your name and address on the reverse so that we can return the card to you
bull Attach this card to the back of the mail piece or on the front if space permits
1 Article Addressed to
Christian Bevan Villiams co Sierra Conservation Center Inmate Reg No V50004 PO Box 497 5100 O-Byrnes Ferry Road Jamestown CA 95327
3 Service Type
Ji( Certified Mail o Registered
o Insured Mail
Express Mail
COD
4 Restricted Delivery (Extra Fee) 0 Y
i Return Receipt for Merchandise
es
2 Article Number (Copy from service label) 7001 0360 0003 2701 4886
PS Form 3811 July 1999 Domestic Return Receipt 102595-00-M-0952
Exhibit B
Postal Return Document
o Agent
o Addressee
D Is delivery address different from item 1 0 Yes
If YES enter delivery address below 0 No
~~lv0-wt)
Ace c~G~i-SENDER COMPLETE THIS SECTION
bull Complete items 1 2 and 3 Also complete item 4 if RestrictedDelivery is desired
bull Print your name and address on the reverse so that we can return the card to you
bull Attach this card to the back of the mail piece or on the front if space permits
1 Article Addressed to
Christian Bevan Villiams co Sierra Conservation Center Inmate Reg No V50004 PO Box 497 5100 O-Byrnes Ferry Road Jamestown CA 95327
3 Service Type
Ji( Certified Mail o Registered
o Insured Mail
Express Mail
COD
4 Restricted Delivery (Extra Fee) 0 Y
i Return Receipt for Merchandise
es
2 Article Number (Copy from service label) 7001 0360 0003 2701 4886
PS Form 3811 July 1999 Domestic Return Receipt 102595-00-M-0952
o Agent
o Addressee
D Is delivery address different from item 1 0 Yes
If YES enter delivery address below 0 No
~~lv0-wt)
Ace c~G~i-SENDER COMPLETE THIS SECTION
bull Complete items 1 2 and 3 Also complete item 4 if RestrictedDelivery is desired
bull Print your name and address on the reverse so that we can return the card to you
bull Attach this card to the back of the mail piece or on the front if space permits
1 Article Addressed to
Christian Bevan Villiams co Sierra Conservation Center Inmate Reg No V50004 PO Box 497 5100 O-Byrnes Ferry Road Jamestown CA 95327
3 Service Type
Ji( Certified Mail o Registered
o Insured Mail
Express Mail
COD
4 Restricted Delivery (Extra Fee) 0 Y
i Return Receipt for Merchandise
es
2 Article Number (Copy from service label) 7001 0360 0003 2701 4886
PS Form 3811 July 1999 Domestic Return Receipt 102595-00-M-0952